Privacy Notice

Last updated February 13, 2024

Renovaro Biosciences (“Renovaro,” “we,” “us,” or “our”) is committed to privacy and data protection. This Privacy Notice applies to all personal information Renovaro collects from you, through websites under the Renovaro domain renovarobio.com and any other Renovaro websites or online services (collectively the “Website”) that link to this Privacy Notice, as well as how we use and protect personal information about you. You may download a copy (.pdf) of this Privacy Notice here.

This Privacy Notice does not apply to any third-party applications or software that integrate with the Website or any other third-party products, services, or businesses (collectively, “Third Party Services”). Third-party services are governed by their own privacy policies. We recommend you review the Privacy Notice governing any Third Party Services before using them.

NOTICE AT COLLECTION

1. WHAT INFORMATION DOES Renovaro COLLECT ABOUT ME AND WHY?

We collect information that identifies, describes, or is reasonably capable of being associated with you (“personal information”). The following discusses the categories of personal information we collect and have collected in the preceding 12 months, the sources we collect information from, and the business or commercial purposes use of personal information about you.

We may collect the following categories of personal information:

  • Such as a real name, postal address, phone number, unique personal identifier, Internet Protocol address, email address, account name, unique identifier of device, or other similar identifiers.
  • Geolocation Data. Such as physical location or movements. We collect your IP address and infer location such as city or postcode therefrom.
  • Internet or other similar network activity. As described in more detail in our Cookie Policy, if you use our Website, we automatically collect information about your browsing and search history, interaction with the features of our Website, and responses to advertisements.

We may use these categories of personal information for the following purposes:

  • To provide you with the Website that you have requested - We may process personal information in connection with any Website we provide and pursuant to our contract to provide such Website, to administer our relationship with you and to carry out our obligations arising from the relationship between you and us, internal accounting and administration purposes, to process payment for purchases or other Website and to create and manage your account.

To provide you with Website we may collect: Identifiers; Your opinions or other information; Commercial information; Geolocation Data; or Internet or other similar network activity.

  • For analytics purposes - For example, we may analyze personal information about you including your location, and Website requested, age, time zone, IP address and URL visited, against our wider customer base for internal business purposes, such as generating statistics and developing marketing plans, based on out legitimate interest to improve our Website and the website. We may also aggregate and de-identify your information to create customer segments and share with our affiliates and partners.

To perform analytics we may collect and process: Internet and network information.

  • To provide you with marketing communications that you might be interested in - If you choose to receive marketing communications from us, we may use personal information about you to keep you up to date with our latest Website, surveys, announcements, upcoming events, sweepstakes, contests and other promotions via our newsletters, emails, or other communications. If you no longer wish to receive these marketing communications, details of how to opt out are described in the section below marked “How do I stop receiving marketing communications?” We send marketing communications based on your consent or our legitimate interest.

To provide marketing communications we may collect and process: Identifiers; or Commercial information.

  • For site optimization and management - For example we may use personal information about you provided to us to:
  • administer the website;
  • ensure the security of our networks and of your information;
  • customize your future visits to the website based on your interests to ensure the most user-friendly online navigation experience;
  • improve the website and our other digital offerings (including to fix operational problems such as pages crashing and software bugs); and
  • provide services to our partners such as tools, analyses, data and insights to see how their website or mobile applications are used.

To support our legitimate interest in site optimization and management we may collect and process: Internet and network information.

  • For service and business development purposes - For example, we will use information we collect from you based on our legitimate interest to improve our Website and develop new Website, features, and capabilities. Data is collected throughout your interactions with the Website that enable us to understand usage and tailor future capabilities.

To support product development, product improvement, and business development we may collect and process: Identifiers; Commercial information; or Internet and network information.

  • For fraud prevention and detection purposes and to protect and defend the rights and property of Renovaro, our employees and business partners.

To support our legitimate interest in fraud prevention and detection we may collect and process: Identifiers; or Internet or other electronic network activity information.

  • To verify your identity - For example, we may collect your real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers to determine if you already have an account with us or comply with a request from you to exercise your rights, as required by law.
  • Information that we collect automatically. When you engage with Renovaro we may use cookies and similar tracking technology to collect the following information about you automatically (for further information please see our Cookie Policy for more information):
  • Internet or other electronic network activity information. Such as browsing history, search history, information on your interaction with a website, application, or advertisement.
  • For example, when you visit the website, engage with Renovaro content or with us digitally, we may collect certain information from your computer, tablet or mobile phone (“Device”) such as your IP address, Device type (i.e. make and model), unique device identification numbers, browser-type and time zone settings
  • We may also collect information about how your Device has interacted with us including: the pages accessed and links clicked; how you navigate to and from the website (such as how you scroll over the site, which parts you click and how long you spend on each page); your preferences, the Website that you have viewed or searched for; and crashes, download errors and response times.
  • Geolocation Data. Such as physical location. We collect your IP address and infer location such as city or postcode therefrom.
  • For example, when you visit the website, engage with Renovaro content or with us digitally, we may collect your broad geographic location (e.g. country or city-level location) from your Device.

Change of purpose

We will only use personal information about you for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use personal information about you for an unrelated purpose, we will notify you and we will explain the business purpose which allows us to do so.

Please note that we may process personal information about you without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

2. HOW LONG DOES Renovaro KEEP MY PERSONAL INFORMATION?

We retain personal information in identifiable form only for as long as necessary to fulfill the purposes for which the personal information was provided to us or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements and similar essential purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information about you, the purposes for which we process personal information about you and whether we can achieve those purposes through other means, and the applicable legal requirements. We are required by law to keep some types of information for certain periods of time (e.g., statute of limitations).

3. FOR WHAT BUSINESS PURPOSE CAN Renovaro USE MY PERSONAL INFORMATION IN THIS WAY?

We are required to satisfy one or more of the reasons set out by applicable data privacy law before we can collect and use personal information about you.

Generally, our business purpose for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally rely on the following reasons to collect and use personal information about you:

  • Performance of a contract

Using your information may be necessary for us to perform our obligations under a contract with you or with a view to entering into such a contract. For example, where you have: (i) purchased or enroll in our Website, we will need to use your information to provide the Website; or (ii) approached us in relation to employment opportunities, the collection and use of personal information about you is necessary to enable us to offer you the job role, process your acceptance of the offer, on-board you as an employee and fulfil our obligations as an employer.

  • Compliance with our legal obligations

The collection and use of personal information about you may be necessary to enable us to meet our legal obligations. For example, to verify your identity and undertake necessary due diligence checks.

  • Pursuing our legitimate interests

Where such processing is not overridden by your interests or fundamental rights, we are permitted to use personal information about you where it is necessary in order to pursue our legitimate interests, for example to operate the website and our other digital offerings, to improve our Website, content and our other digital offerings or to undertake marketing. We may have other legitimate interests and if appropriate we will make this clear to you at the relevant time.

  • Consent

In some limited circumstances, we may rely on your consent to collect and use personal information about you. For example, we may rely on consent: (i) where you have approached us in relation to employment opportunities and have provided us with sensitive personal information, such as information in relation to your racial and ethnic origin, sexual orientation, religion, physical and mental health, disabilities or trade union membership; or (ii) in relation to the sending of e-marketing or communications.

  • If we rely on consent, this will be made clear to you at the time we request your information. You can withdraw your consent at any point by using the mechanism provided at the time, or by contacting us using the contact details provided in the section of this Notice titled “How do I contact Renovaro?”

You may not always be required to provide the personal information that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our Website. Any information that is so required is clearly marked as mandatory. If you would prefer that we not collect certain personal information from you, please do not provide us with any such information, or opt out of providing this information where applicable.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of personal information about you is mandatory or not (as well as of the possible consequences if you do not provide personal information about you).

If we collect and use personal information about you in reliance on our legitimate interests (or those of any third party), these interests will normally be as set out in this Notice; however, if this changes we will make clear to you at the relevant time what those legitimate interests are.

If you have any questions or need further information concerning the business purpose on which we collect and use personal information about you, please contact us using the contact details provided in the section below marked “How do I contact Renovaro?”

4. DOES Renovaro SHARE MY PERSONAL INFORMATION WITH ANYONE?

It is the practice of Renovaro to protect users’ information. Access to our users’ information is restricted to only those employees or agents, contractors or subcontractors of Renovaro who have valid reasons to access this information to perform any service you have requested or authorized, or for any other purpose described in this Privacy Notice. The information you provide will not be sold or rented to third parties.

We may provide personal information about you to:

  • outsourced service providers who perform functions on our behalf, located inside or outside of the jurisdicition in which you reside (in such case, we will use the appropriate legal framework to operate data transfers).
  • our authorized agents and representatives, located inside or outside of your country of residence (in such case, we will use appropriate legal framework to operate data transfers), who provide services on our behalf, such as training service providers;
  • anyone expressly authorized by you to receive personal information about you; or
  • anyone to whom we are required by law to disclose personal information, upon valid and enforceable request thereof.

We will access, disclose and preserve personal information, when we have a good faith belief that doing so is necessary to:

  • comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies, upon valid and enforceable request thereof; or
  • operate and maintain the security of the Website, including to prevent or stop an attack on our computer systems or networks.

Please note that some of the Website may direct you to services of third parties whose privacy practices differ from Renovaro’s. If you provide personal information to any of those services, that data is governed by their privacy statements or policies. Renovaro Biosciences is not responsible for the privacy practices of these other websites. Please review the privacy policies for these websites to understand how they process your information.

How You May Share Personal information

Certain features of the Website may allow you to share information with others. Please do not share personal information about you or the personal information of others through the sharing features. You are the controller of personal information you share through the sharing features of the Website.

5. WHAT ARE MY DATA PROTECTION CHOICES AND RIGHTS?

The privacy laws of some jurisdiciotns may provide their residents with additional rights regarding our use of personal information. The following Section applies to individuals who reside in specific jurisdictions that provide additional privacy rights.

6.1 Your Rights and Choices

Right to Access Specific Information and Data Portability Right. You may have the right to request that we disclose certain information to you about our collection and use of personal information. Once we receive and confirm your verifiable request, we may disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting such information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed personal information for a business purpose, the business purpose for which personal information was disclosed, and the personal information categories that each category of recipient obtained.

Right to Correct Information. You may have the right to request we update personal information about you that is incorrect in our systems.

Right to Delete. You may have the right to request that we delete any personal information about you that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) the personal information from our records, unless an exception applies.

Right to Withdraw Consent. You can withdraw your consent at any point by using the mechanism provided at the time, or by contacting us using the contact details provided in the section of this Notice titled “How do I contact Renovaro?”

Right to Limit Sensitive Personal Information Use. You may have the right to limit the use of sensitive personal information regarding you.

Right to Object to Processing Personal Data. You may have the right to object to the processing of personal data for the purposes of profiling or our legitimate interest.

Non-Discrimination. We will not discriminate against you for exercising any of your rights.

6.2 How to Exercise these Rights

To submit a request to exercise these rights you may use one of these two methods:

For all requests, please clearly state that the request is related to “Your Privacy Rights,” indicate which type of request you are making, and provide your name, street address, city, state, zip code and an e-mail address or phone number where we may contact you. We are not responsible for notices that are not labeled or sent properly or that do not include complete information.

To appeal a decision regarding an individual rights request, please submit your appeal using one of the three methods above. Your appeal should include an explanation of the reason you disagree with our decision. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

You may only make such a request for access or data portability twice within a 12-month period. The verifiable request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verified request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide the personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

6.3 California Shine the Light Law

California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to ir@renovarobio.com or write us at: Renovaro Biosciences, Attention: Privacy Inquiries, 2080 Century Park E, Suite 906, Los Angeles, CA 90067.

6. WHAT IF I ACCESS A THIRD-PARTY SITE THROUGH THE WEBSITE?

The website may contain links to or from third-party sites. Please be aware that we are not responsible for the privacy practices of such third parties. This Notice applies only to the personal information we collect as described above. We encourage you to read the privacy policies of third-party sites you access from links on the website or otherwise visit.

7. HOW DO I STOP RECEIVING MARKETING COMMUNICATIONS?

If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via e-mail, postal mail or telephone about Renovaro Website and events that may be of interest to you, including our newsletter.

Marketing e-mail communications you receive from Renovaro will generally provide an unsubscribe link or instructions on how to opt-out of receiving future e-mail or to change your contact preferences. E-mail communications may also include a link to directly update and manage your marketing preferences. You can also request changes to your contact preferences by contacting Renovaro via email at it-help@cmu.edu or, to stop text messages by texting STOP in response to any text message.

Please remember that even if you opt out of receiving marketing emails, we may still send you important Website information related to your accounts and subscriptions.

8. Cookie Policy

Renovaro uses cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (“Cookies”) to provide the Website and help collect data.

How We Use Cookies

We use Cookies to track how you use the Website by providing usage statistics. Cookies are also used to deliver Renovaro information (including updates) based upon your browsing history and previous visits to the Website. Information supplied to us using Cookies helps us to provide a better online experience to our visitors and users and send marketing communications to them, as the case may be. Information supplied to us upon launching of the Website will enable Renovaro to improve the functionality of the Website.

While this information on its own may not constitute your “personal data”, we may combine the information we collect via Cookies with personal data that we have collected from you to learn more about how you use the Website to improve them.

Types of Cookies

We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on the Website can be grouped into the following categories:

  • Strictly Necessary: These Cookies are necessary for the Website to work properly. They include any essential authentication and authorization Cookies for the Website.
  • Functionality: These Cookies enable technical performance and allow us to “remember” the choices you make while browsing the Website, including any preferences you set. They also include sign-in and authentication Cookies and IDs that enable you to return without additional sign-in.
  • Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the Website. They help us understand which areas you use and what we can do to improve them.
  • Targeting: These Cookies are used to deliver relevant information related to the Website to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit the Website. Some of these types of Cookies on the Website are operated by third parties with our permission and are used to identify advertising sources that are effectively driving users to the Website.

Cookies Set by Third Parties

To enhance our content and to deliver a better online experience for our users, we sometimes embed images and videos from other websites on the Website. You may be presented with Cookies from these third-party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using Cookies or other means. You should consult and review the relevant third-party privacy statement or policy for information on how these Cookies are used and how you can control them.

We also use Google, a third-party analytics provider, to collect information about Website usage and the users of the Website, including demographic and interest-level information. Google uses Cookies in order to collect demographic and interest-level information and usage information from users that visit the Website, including information about the pages where users enter and exit the Website and what pages users view on the Website, time spent, browser, operating system, and IP address. Cookies allow Google to recognize a user when a user visits the Website and when the user visits other websites. Google uses the information it collects from the Website and other websites to share with us and other website operators’ information about users including age range, gender, geographic regions, general interests, and details about devices used to visit websites and purchase items. We do not link the information we receive from Google with any of your personally identifiable information. For more information regarding Google’s use of Cookies, and collection and use of information, see the Google Privacy Notice (available at https://policies.google.com/privacy?hl=en). If you would like to opt out of Google Analytics tracking, please visit the Google Analytics Opt-out Browser Add-on (available at https://tools.google.com/dlpage/gaoptout).

How to Control and Delete Cookies

Cookies can be controlled, blocked, or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser-specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your cookie preferences across these environments.

If you are using a mobile device to access the Website, you will need to refer to your instruction manual or other help/settings resource to find out how you can control Cookies on your device.

Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the Website may not operate properly, and you may not have access to the Website. Renovaro shall not be liable for any impossibility to use the Website or degraded functioning thereof, where such are caused by your settings and choices regarding Cookies.

To learn more about Cookies and web beacons, visit www.allaboutCookies.org.

9. IS MY PERSONAL INFORMATION SECURE?

Renovaro is committed to protecting the security of personal information about you. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal information. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements.

These measures include but are not limited to, technical and organizational security policies and procedures, security controls, and employee training.

We may suspend your use of all or part of the Website without notice if we suspect or detect any breach of security, abuse, or illegal or questionable activity. If you believe that the information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

If we become aware of a breach that affects the security of personal information about you, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, Renovaro will provide any such notice that Renovaro must provide to you at your account’s email address. By using the Website, you agree to accept notice electronically.

10. DOES THIS NOTICE EVER CHANGE?

We may update this Privacy Notice based upon evolving Laws, regulations and industry standards, or as we may make changes to our business including the Website. We will post changes to our Privacy Notice on this page and encourage you to review our Privacy Notice when you use the Website to stay informed.

If we make changes that materially alter your privacy rights, Renovaro will provide additional notice, such as via email or through the Website. If you disagree with the changes to this Privacy Notice, you should discontinue your use of the Website. You may also request access and control of personal information about you as outlined in the Your Rights Regarding Personal Information section of this Privacy Notice.

11. HOW DO I CONTACT Renovaro?

We understand that you may have questions or concerns about this Privacy Notice or our privacy practices or may wish to file a complaint. In such case, please contact us in one of the following ways:

Email: ir@renovarobio.com

Mail:

Renovaro Biosciences
Attention: Privacy Inquiries
2080 Century Park E, Suite 906

Los Angeles, CA 90067