PRIVACY POLICY

This Privacy Policy describes the policies and procedures of Conduct Science, Inc. and its affiliates (“we”, “our” or “us”) on the collection, use and disclosure of personal information from those who use or access conductscience.com, our blog, our branded pages on social media services, or any of the other sites, services, features, content, applications and products we offer in the United States and Canada (collectively, the “Services”). If you are using the Services outside of the United States and Canada, a location-specific privacy policy may apply to you instead, so please check the applicable country-specific website. We receive information about you from various sources, including, without limitation: (i) when you visit our website; (ii) if you register for the Services, through your user account on the Services (your “Account”); (iii) your use of the Services generally, including any purchases that you make on the Services; and (iv) from third party websites and services that interact with our Services.

CONSENT

When you visit www.conductscience.com or otherwise use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as permitted by this Privacy Policy.

The Services are hosted and operated in the United States and are subject to United States law. By using the Services, you acknowledge and agree that any Personal Information (as defined below) that you provide to us is being provided to us in the United States and will be hosted on United States servers.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Services, as well as our treatment of any Personal Information that our partners, service providers and other persons and entities with whom we conduct business (“Business Partners”) share with us or that we share with our Business Partners where permitted by this Privacy Policy.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including, but not limited to, any third party websites, services, products or applications (each, a “Third Party Service”) that you elect to access through the Services, or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content, products, services or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

NOTICE OF EU-US PRIVACY SHIELD PARTICIPATION

Conduct Science, Inc. and its U.S. subsidiary, Conduct Science USA, Inc., both comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information transferred from the European Union to the United States. We have certified to the Department of Commerce that we adhere to the seven Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability, in relation to any Personal Information that we receive from within the European Union (the “Privacy Shield Principles”). Principle 7, the recourse, enforcement and liability principle, provides that we remain potentially liable if a third party processing Personal Information received from the European Union on our behalf processes that Personal Information in a manner that is inconsistent with the Privacy Shield Principles (unless we can prove that we are not responsible for the event giving rise to the damage). Conduct Science, Inc. and Conduct Science USA, Inc. are subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to any failure to comply with the Privacy Shield Principles.

If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. European Union individuals with inquiries or complaints regarding U.S. privacy practices should contact us at [email protected], or can follow the process set forth below in the section titled “What if I Have Questions, Concerns, or Complaints?”.

NOTICE OF WHAT INFORMATION WE COLLECT AND HOW WE USE IT

In connection with certain aspects of the Services, we may request, collect, display and/or disclose some of your Personal Information. From time to time, we may also supplement information we collect from you with other information we collect or with information we receive from third parties, which may include associating non-personally identifiable information with Personal Information. The information we gather, including the types of information described below, enables us (or our Business Partners) to personalize, improve and continue to operate the Services or to provide you with information, products and services that we believe may be of interest to you. Except as otherwise specified below, such information may be used by us (or our Business Partners) in connection with such purposes.

ACCOUNT INFORMATION:

When you create an account on the Services (“Account”), you will provide information that could be Personal Information, such as your email address and password. In addition, you may elect to provide us with your telephone number in order to receive certain information, including, without limitation, promotional offers, from us via Text Message (as defined below). Moreover, if you register for or access the Services using a Third Party Service (such as your social media login credentials, as further described below), we may receive Personal Information that you allow such Third Party Service to share with us. You should consult such Third Party Services’ privacy policies.

We (directly or through our Business Partners) may use such Personal Information and any transaction data relating to your Account or other information relating to your use of the Services for purposes relating to our business or otherwise permitted by this Privacy Policy, including, without limitation, to send you information which we think you might find useful or of interest about our Services. You may unsubscribe from some of these messages by clicking the “Unsubscribe” link at the bottom of any email message from us or by contacting us directly at [email protected], although we reserve the right to contact you when we believe it is necessary, such as for account recovery purposes or in connection with a purchase you have made on the Services.

INFORMATION REGARDING YOUR SOCIAL NETWORKS:

As mentioned above, you may be able to register for or access the Services using a Third Party Service, such as your social media account (e.g., Facebook, Twitter, etc.) (“Social Media Services”). Occasionally, you can also use your Account on our Services to interact with your accounts on Social Media Services. For example, you may be able to access posting and sharing tools on the Services that allow you to post information to your Social Media Services (“Share”), or interact with us through Social Media Services by tagging us or our products on such services. When you use these tools or tag or mention us or our products, or otherwise interact with us through Social Media Services, you acknowledge and agree that some information and content relating to your account on the applicable Social Media Services may be transmitted to us, and that our use of such information is covered by this Privacy Policy, and you hereby allow us to use such information or content in connection with our business, including across our properties and for commercial purposes, or as otherwise permitted by this Privacy Policy. Furthermore, when you use these tools or post to our Services, we may share some of your information and content from our Services with certain Social Media Services, including through our branded pages on such Social Media Services, and such information and content would be subject to the privacy policies of such Social Media Services. Additionally, if a tool, such as the Share tool, is operated by a Third Party Service, the Third Party Service that operates the tool may collect information about your browser or online activity, which would be subject to the Third Party Service’s privacy policy. Therefore, we encourage you to read the privacy policies and other policies of any Third Party Services, including any applicable Social Media Services, that you use in connection with the Services.

We may also collect and receive your social media account login credentials in connection with providing you with the Services, but only if you expressly provide us with such information. We will only use such login information as permitted by this Privacy Policy or as otherwise expressly authorized by you.

USER CONTENT:

Some features of the Services may now or in the future allow you to provide content, such as written comments or reviews, to the Services, including through Social Media Services as described above. All content submitted by you to the Services, including through Social Media Services, may be retained by us indefinitely, even after you terminate your Account. We may use or continue to disclose such content to Business Partners as permitted by this Privacy Policy.

SHIPPING AND BILLING INFORMATION:

If you place an order through the Services, we will ask you for your shipping address, telephone number and credit card information and/or certain other Personal Information about you. We use this information for purposes such as processing and fulfilling your orders, notifying you of your order status and otherwise communicating with you in connection with the Services. We also retain this information as part of your Account for your convenience in making future purchases.

All credit card information and shipping information regularly collected through the Services is encrypted and maintained using industry standard methods designed to ensure its security against loss or theft, including during transmission to our third party payment processing company (the “Payment Processor”), which is currently Stripe. Please note that your financial information, such as your payment method (valid credit card number, type, expiration date or other financial information) is used and stored by our Payment Processor, and use and storage of that information by the Payment Processor is governed by the Payment Processor’s applicable terms of service and privacy policy (for Stripe, available at: https://stripe.com/us/legal and https://stripe.com/us/privacy or any of its successor sites). We may from time to time request and receive some of your financial information from our Payment Processor or from you directly for purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.

COMMUNICATIONS WITH US:

We may collect Personal Information when you communicate with us. For example, if you choose to send us Personal Information by sending us an email, completing a survey or contacting our customer service department, we will keep a record of that communication and may collect and use Personal Information that you provide to us in accordance with this Privacy Policy. If we communicate with you via email, SMS, MMS or other text message (“Text Message”) or push notifications (to the extent you permit us to do so), we may collect information regarding such communications, such as confirmation when you open an email, read a Text Message or receive a push notification. We use this information for purposes such as to operate and improve our Services, including our customer service, or as otherwise permitted by this Privacy Policy. If you opt to have promotional offers from us sent to your mobile device, we may send you Text Messages regarding such promotional offers to the telephone number you provided to us. To opt out of receiving promotional Text Messages from us, reply “STOP” to any such message.

INFORMATION COLLECTED AUTOMATICALLY:

Generally, the Services automatically collect certain usage information, such as the number and frequency of visitors to the Services that we may use in aggregate or anonymized form. This type of aggregate data enables us and third parties authorized by us to better understand our Services, such as by helping us figure out how often individuals use parts of the Services so that we can analyze and improve them. We also automatically receive and record information from your web browser when you interact with the Services, such as your IP address, browser type, ISP, referring/exit pages and cookie information. We may also collect device-specific information about the device you use to access the Services, such as unique device identifiers, network information and hardware model, as well as information about how the device interacts with our Services and information about where you access the Services from. This information is used for purposes such as facilitating analyses of data concerning registered and unregistered users’ interaction with the Services (e.g., what links you have clicked on). Non-Personal Information (defined below) that we automatically collect may be combined by us or our Business Partners with other information about you, including Personal Information, and used in connection with our business or to provide you with information, products and services that we believe may be of interest to you.

INFORMATION COLLECTED USING COOKIES:

Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. Some cookies last only for the duration of your web session and expire when you exit the browser, while other cookies may remember you when you return to the Services, as you continue your web session and after you exit the browser. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit and otherwise use the Services through the Internet, for purposes such as analyzing trends and learning about our customers and user base. For example, we use some services from third party vendors, such as Google Analytics Advertising Features, operated by Google, Inc. (“Google”) (which may include, without limitation, Remarketing with Analytics, Demographics and Interests reporting, Segments and DoubleClick Campaign Manager), that use cookies, including first party cookies (such as the Google Analytics cookie) and third party cookies, for purposes such as to inform, optimize, remarket and serve ads based on your visits to the Services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You may find additional information about Google Analytics at http://www.google.com/policies/privacy/partners/. You have the option to opt out of Google’s use of cookies by changing your settings through Google Ad Settings, visiting the Google advertising opt-out page at http://www.google.com/policies/technologies/ads/ or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/ or through the Network Advertising Initiative opt-out page described below.

We may combine Non-Personal Information (defined below) collected through cookies or other automatic means with other Personal Information that we have about you, for example, to tell us who you are or whether you have an Account.

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide whether to accept each new cookie in a variety of ways. We recommend that you leave cookies active because they enable you to take advantage of some of the most attractive features of the Services.

You can learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information about cookies and how to block cookies using different types of browsers.

AGGREGATE INFORMATION:

We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This Aggregate Information is not Personal Information and cannot be tied back to you, your Account or your web browser, and we may use or disclose such Aggregate Information to a third party for any purpose.

ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS:

We may use one or more Third Party Services, such as Google Analytics, ad servers, ad agencies, ad technology vendors and research firms, for analytics and advertising services such as to provide audience measurement and analytics services to us, to serve ads on our behalf, to track and report on the performance of those advertisements, to collect information via the Services for marketing and advertising purposes, and to identify people who are most likely to respond to our advertisements. Furthermore, our advertisements may be targeted to users who fit a certain general profile category and may be based on (i) anonymized information inferred from information provided to us by a user, including Personal Information (e.g., gender or age), (ii) user activity and usage patterns with respect to the Services or (iii) user activity on Third Party Services.

In connection with these services, we and/or these Third Party Services may collect and use information about your visits to the Services and Third Party Services and your interaction with our products, the Services and other Third Party Services using cookies, web beacons, pixel tags, SDKs and other technologies (collectively, “Tracking Tools”) to identify your device and track your activities when you visit or use our Services, as well as when you visit other online sites and services, including over time, across different websites and apps and across various devices, and this information may include information such as your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. For example, web beacons allow us and Third Party Services to provide anonymized, aggregated auditing, research and reporting for us and for other advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from an ad network’s servers, these Third Party Services can view, edit or set their own cookies, just as if you had requested a web page from their site.

As a result of some of these services, targeted or interest-based advertisements or recommendations may appear on our Services or other sites or services that you visit or access (known as “behavioral advertising”). By accessing or using the Services, you agree that you are giving us your consent to set and access Tracking Tools and to track your activities and use of the Services through these Tracking Tools in accordance with this Privacy Policy. If you would like more information about this practice and how to opt out of having your information used for certain behavioral advertising purposes and by certain participating parties, please (a) visit http://www.networkadvertising.org/choices/ or www.aboutads.info/choices (for web-based advertising and collection) and (b) visit http://www.networkadvertising.org/mobile-choice or download the Ghostery mobile application (for mobile advertising and collection). Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive.

At present, the Services contain Atlas Universal Tags and utilize Google Analytics Advertising Features including Google Display Network Impression reporting. You can opt out of the Atlas Universal Tags at the links in clauses (a) and (b) of the immediately preceding paragraph, and you can opt out of the Google Display Network Impression reporting by visiting https://tools.google.com/dlpage/gaoptout/.

Please note that even if you choose to opt out of having information collected for behavioral advertising purposes, you may still see advertisements while you are browsing online; however, such advertisements may be less relevant to you and your interests. Please note that if you opt out of targeted advertising, we may still track your visits to our Services for analytics, operations and security purposes.

ONWARD TRANSFER: HOW, AND WITH WHOM, IS MY INFORMATION SHARED?

In addition to the sharing of your information as set forth above, we may also share your information in the following ways:

PUBLIC INFORMATION ABOUT YOUR ACTIVITY ON THE SERVICES:

Some of your activity on and through the Services may be public, such as content that you have posted publicly in connection with the Services, including on your social media accounts. Registered users may have some of the information about their activity on and through the Services associated with their Accounts.

INFORMATION SHARED WITH OR BY OUR BUSINESS PARTNERS:

We contract with various Business Partners for services related to our business, including, among other services, shipping, name and address verification, email distribution, market research, third party advertising, fraud prevention, promotions management and payment processing (as discussed above). We provide our Business Partners with only the information they need to perform their services and we work closely with them to ensure that your privacy is respected and protected. We may also share your information, which may include Personal Information, with Business Partners in connection with providing you with information, products or services that we think may interest you, and we or such Business Partners may contact you about their products and/or services. For clarity, only those of our employees and Business Partners who need access to your credit card information in order to perform their duties are allowed such access.

We may share IP address and similar device or other automatically collected information with our Business Partners, and as otherwise permitted by this Privacy Policy. We may also share information with our Business Partners who provide analytics, marketing, fulfillment, fraud detection and prevention and other services, or who may contact you about their products and services. Such information may include (i) Personal Information, (ii) information that is not Personal Information and/or (iii) information that is derived from Personal Information but has been anonymized so that it is no longer personally identifiable (“Non-Personal Information”). We use and share this type of data for purposes such as helping us and our Business Partners understand how and how often people use our and their respective services or websites, which facilitates improving our Services, their services and how our Services interface with their services. In addition, these Business Partners may share with us information about you that they have independently developed or acquired in accordance with their own privacy policies and practices, for instance, in order to enhance our understanding of your interests and preferences so that we can make our Services more relevant to you and provide you with information about products and services we think may interest you. We may use such information for any purpose permitted by this Privacy Policy.

Unless set forth in this Privacy Policy or otherwise communicated to you, our Business Partners do not have any rights to use Personal Information beyond what is necessary to assist us or provide their services. You hereby consent to our sharing of Personal Information with our Business Partners.

INFORMATION DISCLOSED PURSUANT TO BUSINESS TRANSFERS:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is often one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Privacy Policy.

INFORMATION DISCLOSED FOR OUR PROTECTION AND THE PROTECTION OF OTHERS:

We also reserve the right to access, read, preserve and disclose any information as we reasonably believe is necessary to: (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof or thereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to user support requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

INFORMATION WE SHARE WITH YOUR CONSENT:

In addition to the disclosures described in this Privacy Policy, we may also share your information, which may include your Personal Information, in additional ways if you consent to such sharing.

IS INFORMATION ABOUT ME SECURE?

Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer, browser and any other device you use to access your Account, and by signing off after you have finished accessing your Account.

We seek to protect Account information and take steps to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We otherwise store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, whether such information is Personal Information or otherwise.

ACCESS: WHAT INFORMATION OF MINE CAN I ACCESS?

If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Conduct Science, Inc., 161 Avenue of the Americas, Floor 8, New York, New York 10013.

WHAT CHOICES DO I HAVE REGARDING MY INFORMATION?

1. You can use some of the features of the Services without registering, thereby limiting the type of information that we collect. You can always opt not to disclose certain information to us, but please note that certain information may be needed to take advantage of some of our Services.
2. You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us.
3. Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites and web applications and services (including, without limitation, behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. The Services do not support Do Not Track requests at this time, which means that we may collect information about your online activity both while you are using the Services and after you leave our properties. Remember that this is just our Do Not Track policy, and we cannot and do not make any promises about how third parties react when you set this signal on your browser.
4. You can choose to opt out of certain communications or communication methods; however, if you do so, you may not be able to take advantage of some of our Services’ best features.
5. You can opt out of certain Tracking Tools by following the steps set forth in the section above titled “Analytics and Advertising Services Provided by Others”.

HOW CAN I DELETE MY ACCOUNT?

Should you ever decide to delete your Account, you may do so by emailing [email protected]. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account.

WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. Unless we notify you otherwise, each user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

WHAT IF I HAVE QUESTIONS, CONCERNS OR COMPLAINTS?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to [email protected]. We will make every effort to resolve your concerns.

In compliance with the Privacy Shield Principles (where applicable), we commit to resolve complaints about your privacy and our collection or use of your Personal Information. We have further committed to refer unresolved Privacy Shield complaints to JAMS, Inc. (“JAMS”), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may contact or visit JAMS by visiting www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for residual claims about whether we have violated our obligations to you under the Privacy Shield, and if that violation remains fully or partially un-remedied.