Privacy Policy

Ichor Life Sciences, Inc. (the “Site”, “we” or “ICHOR”) is strongly committed to protecting the privacy of its website users (USERS). The majority of the website can be navigated without providing personal information. At times, though, additional information about USERS is needed to provide the information or services USERS request. To protect USERS’ privacy, this notice explains ICHOR’s online information practices and the options USERS can select about what information is collected and used.

This Privacy Policy describes how ICHOR collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

Collecting Personal Information 

ICHOR may collect the following types of personally identifiable information through this website: name, title, contact details including e-mail address, and telephone numbers. ICHOR may collect additional information when USERS register to access services available through the website.

On some pages, USERS may opt to provide information about themselves. For example, USERS are interested in (a) an employment opportunity at ICHOR; or (b) having ICHOR participate at an event. The information requested from USERS will be based on the area of interest.

On occasion, ICHOR may request that USERS voluntarily participate in a survey or poll such as feedback on website content or services. Responses will be anonymous unless USERS opt in to being contacted by email to provide further information regarding the survey.

In order to improve the design and content of the website and to enable ICHOR to better personalize USERS’ experiences, ICHOR may collect certain technical information about USERS, such as the IP address, the type of browser or operating system USERS are using, or the domain name of the USER’s Internet service provider.

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Salesforce enables our customers to build trusted relationships while protecting individual privacy through compliance with global data protection laws. You can learn more on how Salesforce uses your information here: https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Privacy/dpia-and-salesforce-services.pdf

Device Information

• Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
• Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
• Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
• Disclosure for a business purpose: shared with our processor Shopify. 

Sharing Personal Information 

ICHOR uses information to enable USERS to receive access to products, products and services on-line, obtain information about products and services, and to receive updates, participate in surveys or questionnaires posted on the website, provide USERS with opportunities ICHOR believes may be of interest to USER, or to respond to USER requests.

ICHOR does not share personally identifiable information with unrelated third-parties who are not covered by this privacy statement without USERS’ prior permission, except to the extent reasonably necessary to: (i) correct technical problems and malfunctions; (ii) protect the security and integrity of the website; (iii) protect the rights, interests and property of ICHOR and of others; (iv) comply with laws or to respond to judicial process; or (v) provide information to law enforcement agencies or for an investigation of a matter as applicable, or otherwise as required or permitted by law.

• We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

We also use this to retarget relevant advertisements that are personalized for you.

Children’s privacy

Protecting the privacy of the very young is especially important. For that reason, ICHOR does not intend to collect or maintain information from those ICHOR knows are under 13 years of age, and no part of the website is structured to attract anyone under 13.

Email Marketing

Ichor Life Sciences, Inc. shares information with Mailchimp, an email marketing automation platform service for managing mailing lists and creating email marketing campaigns to send to customers and prospects.

What does Mailchimp do to comply with the GDPR?

• Appointed a Data Protection Officer (DPO) to oversee their compliance program.
• Continuously review security measures to ensure any personal data collected and process on their systems are adequately protected.
• Ensure the Privacy Policy clearly explains Mailchimp’s commitment to the GDPR, is transparent about how they use personal data, and gives individuals information about how they can exercise their data subject rights.
• Incorporate the EU’s Standard Contractual Clauses in Mailchimp’s Data Processing Addendum which automatically forms part of their Standard Terms of Use and applies to customer data protected by EU laws.
• Provide customers with GDPR-ready terms in our Data Processing Addendum and update our contracts with third party vendors to ensure they are GDPR-compliant.
• Maintain formal processes around data subject rights to ensure Mailchimp can help customers fulfill requests they receive.
• Respond to and fulfill data subject rights requests in their role as a controller.
• Complete Data Protection Impact Assessments to identify and minimize any risks from Mailchimp’s processing activities.
• Maintain accurate records of their processing activities, both as a processor and controller of personal data.
• Mailchimp pays close attention to regulatory guidance around GDPR compliance and making changes to our product features and contracts when they’re needed.
• Certify annually with the EU-U.S./Swiss-U.S. Privacy Shield Frameworks and continue to protect EEA, UK, and Swiss data in compliance with the Privacy Shield Principles.

Behavioral Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

• We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

• FACEBOOK – https://www.facebook.com/settings/?tab=ads
• GOOGLE – https://www.google.com/settings/ads/anonymous
• BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Using Personal Information 

We use your personal Information to provide our services to you, which includes: offering products for sale, and keeping you up to date on new services and offers.

Lawful Basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

• Your consent;
• The performance of the contract between you and the Site;
• Compliance with our legal obligations;
• To protect your vital interests;
• To perform a task carried out in the public interest;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention 

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Your Rights

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use the following cookies to optimize your experience on our Site and to provide our services.

Reporting and Analytics

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioral Advertising” section above.

Do Not Track 

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of https://help.hotjar.com/hc/en-us/categories/115001323967-About-Hotjar

Changes 

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact

If USERS wish to access, correct, update or request removal of any of the information USERS provided, or if USERS have any questions regarding this statement or would like more information on ICHOR’s privacy practices, please contact us at:  info@ichorlifesciences.com For investor relations queries, please contact  info@ichorlifesciences.com.

For queries by mail, please write: ICHOR LIFE SCIENCES, INC. 2561 US Route 11, LaFayette, NY 13084

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority.