CovationBio Privacy Policy

Last modified: June 20, 2023

Covation Biomaterials LLC and its corporate affiliates (collectively referred to as “CovationBio,” “we,” “us,” or “our”) respect your privacy and commit to protecting it through our compliance with the practices described in this notice.

This Privacy Policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal information we may collect from you or that you may provide when you visit our U.S.-based website, www.covationbio.com, including any microsites, brand websites (such as www.sorona.com), Ceridian HCM Holding, Inc’s (“Ceridian”) Dayforce system as utilized by CovationBio for recruitment/hiring purposes, mobile versions of such websites/systems or other digital properties, communications, or forms that link or refer to this notice (collectively, the “Website”). This Privacy Policy also applies to personal information that CovationBio collects in connection with CovationBio’s pages on social media sites, such as Facebook®, LinkedIn®, or others (collectively referred to as our “Social Media Pages”).

This Privacy Policy is intended to assist you in understanding what information we gather about you when you visit and use our Website or Social Media Pages and how we use that information. Please read this notice carefully to understand our policies and practices for processing and storing your personal data. The Website is provided subject to this Privacy Policy, as it may be modified by us at any time and posted on this Website. By engaging with our Website, you accept and consent to the practices described in this notice. Your continued engagement with our Website after any such revisions indicates that you accept and consent to them, so please check the notice periodically for updates.

 

Information We Collect

We collect and use various types of information about our customers and Website visitors including:

  • Location: We use various technologies to learn your geographic location, including by collecting your IP address or other device information, which may depend on your device’s settings for location services.
  • Device Information: When you visit our Website, interact with our Social Media Pages or online ads, or open our emails, we learn about your browser, login information, browser type and version, time zone setting, device type, IP address, internet service provider, and other technical information about your device.
  • Contact Information: Personal data that we could reasonably use to directly or indirectly identify you, such as your name, postal address, email address, telephone number, social security number on Dayforce, and information such as your social media account information.
  • Call, Contact, and Email Records: If you call, contact us through the Website, or email our team, we may keep records of those conversations.
  • Website Interactions: We collect information about your interactions with our Website.
    • Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.

    • Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream information to, through, and from our Website (including date and time), products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page

  • Submitted Content: We collect any content you submit to our Website, Social Media Pages, or to us.

How We Collect Information

We may collect the information described above directly from you, from third parties we partner with, or through cookies or other automated means. These sources may include:

  • Direct Interactions: We collect information directly from you by filling in forms or by corresponding with us by phone, email or otherwise. This includes information you provide when you create an account, subscribe to our service, search for a product, place an order, enter a competition, promotion or survey, submit information, visit our Website, upload content, sign up for communications; or use or like our Social Media Pages.
  • Automated technologies or interactions: Certain information is automatically collected from your device or browser and analyzed when you visit our Website, interact with our Social Media Pages or online advertising, or open our emails. We collect this information by using cookies, server logs, and other similar technologies.
    • Cookies: We use cookies (small data files stored on your device or browser), pixel tags (tiny graphic images embedded in a website or email), and other similar technologies to automatically collect information when you visit our Website or interact with our emails. Through the use of cookies, we may link information about your interactions with our Website or emails over time. We also contract with third party advertising or analytics companies to serve you online ads on other websites. These companies use cookies or similar technologies to collect information about your interactions with our Website and interactions with other websites. These advertising companies may use and share the information gathered to deliver ads more tailored to your interests. We receive aggregate information from these third parties to understand our advertising effectiveness. Any information collected by us or by third parties through the use of cookies or similar technologies may be linked with other information we collect about you.
    • Web Beacons: Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or
      opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Third Parties or publicly available sources: We work with third parties who provide services to us such as analytics, distributors, or advertising companies. Your information may be collected and processed independently in accordance with the third party’s own privacy notices. These third parties share information they have collected with us.
  • Social Media Platforms: Social media platforms share information with us. You can learn more about how social media platforms collect and use your information by reviewing their privacy policies and settings.
  • User contributions: You also may provide information for us to publish or display (”post”) on public Website areas or transmit to other Website users or third parties (collectively, “User Contributions”). You submit User Contributions for posting and transmission to others at your own risk. Although [we limit access to certain pages/you may set certain privacy settings for User Contributions by logging into your account profile], please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of any Website users with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

How We Use Collected Information

We may use the information we collect for the following business purposes:

  • Understanding Our Customers: Analyzing your activity with us (including your interactions with our Website, Social Media Pages, and emails or other forms of communication), and monitoring the effectiveness of our advertising and communications.
  • Personalization: Using your preferences and other collected information to personalize our relationship with you, including presenting customized communication, advertising, and experiences on our Website, emails, and ads on social media.
  • Communications: Communicating with you about our services and responding to your inquiries.
  • Hiring: recruiting and hiring.
  • Sales/Operations: To manage and develop our business and operations, to fulfill an order for products or services, provide after-sales support and customer service or to keep accounting records and evidence of sales.
  • Customer Experience: Serving content on our Website and Social Media Pages, developing our products and services, and constantly improving our customers’ experience, including but not limited to, troubleshooting customer service issues and improving site functionality.
  • Security: Protecting the security of the Company website and Company confidential and proprietary information and to protect our customers from fraud, security threats, and other illegal or harmful activity.
  • Legal Obligations: Complying with legal and regulatory requirements and responding to requests from courts or other government bodies.

We may also use your personal information for the following additional purposes:

  • Advertising: Presenting advertising online and via email, or other communication channels, about the Company’s products, services, events, promotions, and website, including through partnerships with social media platforms and internet search engines.

If you do not want us to use your information for these additional purposes, you may opt out at any time by providing written notice to unsubscribe@covationbio.com or by unsubscribing to the electronic communication.

Before using or disclosing personal information for a purpose not previously identified, we will identify the new purpose and take appropriate action to comply with applicable law, which may include obtaining your consent unless the use or disclosure is authorized or required by law.

We may use non-personal data for any business purpose.

Marketing

We use information to send you product or promotional advertising unless you have opted out of receiving product or promotional advertising, and specifically:

  • To send you marketing communications containing news, information and updates about our products and services, offers, promotions and special events, and other marketing communications that may be of interest to you (by text message or email);
  • To customize your experience with us to your interests and purchase history, notably via profiling. We use your profile to anticipate the products and services of most interest to you and that you are most likely to purchase or recommend to other people. As a result, you may receive marketing materials focused on certain products and services, and not others.

How We Share Information with Service Providers and Third Parties and for What Purposes

We may share personal information with third parties for certain purposes. For example, we share personal information with:

  • Service Providers: We partner with third parties to assist with many aspects of our business, including advertising, analyzing your interests and activity on our Website and Social Media Pages, and helping us communicate with customers. These third parties may provide services related to any of the purposes described in How We Use Collected Information, and we may share with them any types of information described in Information We Collect. We may also receive information collected by these third parties and combine it with the information we have collected. Your information may also be collected and processed by third parties, such as social media platforms, who will process your information independently in accordance with their own privacy notices. We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
  • Marketing Providers: We partner with third parties to assist with the advertising and marketing of our business. We may share with them the types of information described in How We Use Collected Information.

We may share personal data with other third parties for certain purposes, including:

  • Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
  • Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization or industry associations that require such data). We require these third parties to keep that personal data confidential and use it only for the contracted purposes. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CovationBio, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection. We will disclose information about you, including to government bodies or law enforcement agencies, when we believe it to be necessary for compliance with the law or to protect our Website users, our Website, or the public.
  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • For any other purposes that we disclose when you provide the data.
  • With your consent.

Your Privacy Choices

You can control the information we collect and use in the following ways:

  • Consent: We will obtain your consent to collect, use or disclose personal data, except where we are authorized or required by law to do so without consent. Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your personal data collected/used/disclosed for optional purposes following reasonable notice of same) or otherwise. By providing personal data to us, you agree that we may collect, use and disclose such personal data as set out in this Policy and as otherwise permitted or required by law. For example, we may collect, use or disclose personal data without your knowledge or consent where the personal data is publicly available from a prescribed source, such as a telephone directory, it is reasonable to expect that obtaining consent would compromise an investigation or proceeding.
  • In cases where you have given consent, you may withdraw your consent at any time, subject to legal or contractual restrictions, provided that reasonable notice of withdrawal of consent is given to us. On receipt of notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include or inability to provide services for which that information is necessary.
  • Location information: You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Website from accessing your location information. Note that some services may not be available if you disable location-based services.
  • Emails: You can unsubscribe from marketing emails by clicking the unsubscribe link in the footer of such email.
  • Social media: This privacy policy does not cover the privacy and security practices of social media platforms on which CovationBio has Social Media Pages. Please review the terms, policies, and settings of those social media platforms if you have questions about how they collect and use your data.
  • Online advertising: For information about opting out of third-party advertising, visit: NAI Opt-Out or DAA. When you click on either link, you will leave this Website for a separately managed online site where you can specify your preferences. You can also click on the icon that may appear on some of our advertising served through this technology. We may use more than one third party company for placing this advertising, which would require you to opt out of each company.

Access, Change, Restrict, or Delete Your Personal Information

If you would like to request to review, correct, update, restrict, object to , delete, or otherwise limit CovationBio’s use of, your personal information that has been previously provided to CovationBio, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law) you may contact Legal@CovationBio.com.

For individuals located in the European Union, our EU-based representative is Bengi Ergon Kaya.

In your request, please make clear what information you would like to have changed, whether you would like to have your personal information restricted from a CovationBio database or otherwise let CovationBio know what limitations you would like to put on CovationBio use of your Personal Information. We will try to comply with your request as soon as reasonably practicable.

Children’s Privacy

CovationBio is committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities. CovationBio does not target the Website to children less than 16 years of age or knowingly collect Personal Information from children for the purpose of selling products or services. If you are under 16, do not use or provide any information on this Website or on or through any of its features.

CovationBio does participate in select educational programs such as science and environmental awareness in support of schools and communities.

Data Security

The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. We store all personal data you provide to us behind firewalls on servers employing security protections.

The safety and security of your information also depends on you. We ask that you do not send to CovationBio, and that you do not disclose to CovationBio, any personal data (for example, information related to home address, date of birth, location data or physical, physiological, genetic, economic, cultural, or social identity) on or through the Website or otherwise.

Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website. If you have concerns about the security of your account, or wish to alert us of any potential vulnerabilities, please contact Legal@CovationBio.com.

Supported Web Browsers and Do Not Track Signals

We recommend that you use the latest web browser versions to optimize your experience. Older web browser versions may not be able to access or utilize all pages on our website as intended.

CovationBio may not be able to receive or honor web browser “Do Not Track” signals and our website may continue to collect information in the manner described within this Privacy Policy.

Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or allowed by law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide requested services to you; and
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

If we cease to have an ongoing relationship with you and provide requested services to you, we will delete your personal information after 2 years. We will take due care when destroying personal information so as to prevent unauthorized access to the information.

Cross-Border Transfer

Your personal information may be stored and processed in any country where we have facilities or where we have engaged a service provider, including to the United States, which may have different data protection rules than in your country.

If you are located in the European Economic Area (EEA): Some non-EEA countries are recognized by the European Commission (EC) as providing an adequate level of data protection according to EEA standards (see the full list of countries). For transfers from the EEA to countries not considered adequate, we have put in place adequate measures, such as standard contractual clauses adopted by the EC to protect your personal information. You may obtain a copy of these measures by contacting Legal@CovationBio.com (see below).

CovationBio's Use of Analytics

  • CovationBio may use Google Analytics provided by Google, Inc. ("Google") which uses cookies (text files placed on your computer) to help CovationBio understand how you may use the Website:
  • The information generated by the cookies about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the U.S. and other countries (the servers are owned by Google).
  • Google will use this information to provide data about your use of the Website that allow creation of reports on website activity for website operators and providing other services relating to website activity and internet usage.
  • Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf.
  • Google will not associate your IP address with any other data held by either company.
  • You may refuse the use of cookies by selecting the appropriate settings on your browser. However please note that if you do this, you may not be able to use the full functionality of the Website.

For German users, to opt out of Google Analytics tracking entirely, please click here

  • You can learn about Google's practices by clicking here and opt out of them here

CovationBio may potentially use other analytical tools such as Adobe, ScanTrust, etc.

Ceridian’s Dayforce Terms and Conditions

The terms and conditions outlined in this policy also describe the type of information we may collect from you or that you may provide when you visit our Recruiting website, hosted by Ceridian Dayforce, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

The Ceridian Dayforce recruitment platform, which can be accessed via the U.S. -based website www.covationbio.com, is for applicants for CovationBio employment who are based in the United States of America only.

If you would like to access and correct your applicant information on Dayforce, you can review and change your personal information by logging into the Dayforce website and visiting your account profile page. If you delete your profile from the Dayforce website, copies of this data may remain viewable in

cached and archived pages or might have been copied or stored by other Dayforce users. Further information about Ceridian’s privacy policy and practices can be found here.

California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://www.oag.ca.gov/privacy/ccpa.

California's "Shine the Light" Law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to Legal@covationbio.com or write us at: 800 Prides Crossing, Suite 201, Newark, Delaware 19713.

Website Terms and Conditions

This Privacy Policy constitutes an integrated part of CovationBio’s terms and conditions located in the Legal Notice link.

Updates

We reserve the right to modify, alter, or otherwise update this Privacy Policy at any time, so we encourage you to review this policy from time to time. Changes to this Privacy Policy are effective at the time they are posted and your continued use of our sites after posting will constitute acceptance of, and agreement to be bound by, those changes. If we make any material changes to our privacy practices, we will update this Privacy Policy and change the effective date at the top of this page.

Questions?

Please send your privacy-related questions, comments, and concerns to us via email at Legal@CovationBio.com. You may also contact us by mail at the following:

CovationBio

Attn: Legal Department

800 Prides Crossing

Suite 201

Newark DE 19317