Updated: 15 October 2018

Verso Biosciences, Inc. (“us”, “we”, or “our”) operates the www.versobio.com website and the MarkerLab Platform available at www.markerlab.io (collectively, the “Services”).  This Privacy Policy describes our information collection, use and disclosure practices in connection with the Services and with respect to information we may collect from you by telephone, email or other electronic messaging.  By using the Services or submitting personal data to us by any other means, you acknowledge that you understand and agree to be bound by this Privacy Policy, and agree that we may collect, process, transfer, use and disclose your personal data as described in this Privacy Policy.

This Privacy Policy does not apply to any third party application or site that may be accessed via links on our Website or apps. We are not responsible for the privacy practices or content of any site (including any business partner or dealer website) you access through any external links available through the Services. Please consult the privacy policies of those sites for more information about their practices.

1. INFORMATION WE COLLECT

1.1 During your use of the Services or through other communications with us, personal data may be collected and processed by us. In general, we collect personal contact information (e.g. name, company, address, telephone number and e-mail address), which you knowingly provide either by registration, survey, answering questions or otherwise for use in our commercial relationship. At times we may collect additional personal data that you voluntarily provide, including, but not limited to, job title, additional contact information, date of birth, and professional affiliations.

1.2 When you access our Services, we may automatically (i.e., not by registration) collect non-personal data (e.g. type of Internet browser and operating system used, domain name of the website from which you came, number of visits, average time spent on the site, pages viewed). We may use this data and share it with our service providers to monitor the attractiveness of our websites and improve their performance or content. In this case, processing is performed on an anonymous basis and at our discretion.  In addition, certain online technical applications or other interactions you have with us may require the entry of business and technical data. By providing the requested information, you are consenting to the processing and storage of such information by us. Unless we are advised that you want this information removed from our server(s), such information may be retained by us and used for future commercial communications. A request for removal of this information can be made at the contact information provided below.

1.3 Cookies are information stored automatically on a website user’s computer. When a user accesses the Services, we may store some data on the user’s computer in the form of a “cookie” to automatically recognize the user upon future visits to the Services. We will make reasonable efforts to ensure compliance with the laws and regulations of relevant jurisdictions with regard to cookies.

2. HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us for a variety of purposes, including, without limitation: (i) to provide our Services and their content to you; (ii) to allow you to participate in interactive features in connection with the Services; (iii) to provide you with information or services that you request from us; (iv) for our own marketing purposes; (v) to fulfill any other purpose for which you provide it; (vi) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; (vii) to notify you about changes to our Services; (viii) to follow-up with you about services or products provided to you by us or our business partners; (ix) to administer your account(s); and (x) to improve our Services.

3. HOW WE SHARE YOUR INFORMATION

In compliance with applicable laws and regulations we may: (i) share personal data with our third party providers to better understand your business needs and how we can improve our products and services; (ii) use third party service providers to assist us in collecting, assembling or processing personal data in connection with services related to our business relationship; (iii) engage a third party on our behalf to contact you about an offer from us in support of your business needs or to conduct surveys to understand better our customers’ needs, and for other marketing and promotional activities; (iv) share personal data with contractors, service providers, and other third parties we use to support our business; (v)  transfer your personal data to an affiliate, buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding; and (vi) share your personal data with third parties to enforce or apply our Terms of Use and other agreements, including for billing and collection purpose.  We do not share your personal information with third parties for the third parties’ direct marketing purposes without your consent.

4. EU DATA PRIVACY RIGHTS

4.1 If our processing of your information is subject to the European Union’s General Data Protection Regulation 2016/679 (“GDPR”), we may have obligations to you and you have additional rights under the GDPR.   

We will process your personal data in order to provide our website to you. The lawful bases under GDPR for processing your data may include:   

  • when you have given consent;
  • when processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; or
  • when processing is necessary to protect our legitimate interests or that of a third party, except where such interests are overridden by your interests or fundamental rights.

We may rely on more than one of the lawful bases under GDPR for processing your information described above.

4.2 If you are a resident of the EU, the GDPR grants you certain legal rights. In particular, you have the following rights:

  • the right to confirmation as to whether we process your personal data and the right to access such personal data;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability; and
  • the right to withdraw consent.

In some circumstances, these rights are qualified or limited by countervailing interests. Nevertheless, if you wish to exercise any of these rights, please contact us at privacy@versobio.com.

You also have the right to lodge a complaint with the relevant EU supervisory authority.

4.3 Our legal bases for collecting and using the personal information described in this Privacy Policy from EU residents depends on the personal information we collect and the specific context in which we collect it.  We may process an EU resident’s personal information because: (i) we need to perform a contract with you; (ii) you provided your consent; (iii) the processing is in our legitimate interests and it is not overridden by your rights under applicable law; or (iv) to comply with applicable law.

5. CHILDREN’S PRIVACY

Our Services not intended for children under the age of 13 and we do not knowingly collect personally identifiable information from anyone under the age of 18. If you are the parent or guardian of a person under 13 and believe that person provided us with personal information, please contact us at: privacy@versobio.com.  If we become aware that we have collected personal information from children under the age of 13 without verification of parental consent, we will use commercially reasonable efforts to erase or otherwise destroy that information from our systems.

6. CALIFORNIA PRIVACY RIGHTS

6.1 If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to a third party for the third party’s direct marketing purposes. To make such a request, please send an email to privacy@versobio.com or write us at: Verso Biosciences, 1224 Fairfax Avenue, San Francisco, CA 94124.

6.2 Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. 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. In some cases, third parties may be able to collect information about a user’s online activities over time and across different websites when he or she uses the Services.

7. SECURITY

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of personal information in our custody or control. However, no method of transmission over the Internet, or method of electronic storage is 100% secure and we cannot guarantee that these safeguards will prevent the unauthorized access, use or disclosure of your personal information.

8. CHANGES TO THIS POLICY

We will post any changes we make to our Privacy Policy on this page with a notice on this page. If we make changes to how we treat our users’ personal information, we will notify you by email or through a notice on available via the Services. The date the privacy policy was last revised is identified at the top of this page.

9. QUESTIONS OR COMMENTS

To ask questions or comment about this Privacy Policy, contact us at privacy@versobio.com.