Privacy Policy

Last Updated: September 2 2022

Impact Biosystems, Inc. (“Impact Biosystems” or “we,” “us,” or “our”) is committed to respecting your privacy. This Privacy Policy (“Policy”) describes how Impact Biosystems collects and uses Personal Information in connection with your use of this website, located at https://www.thepact.com/, our Pact Mobile Application, and the features, functionalities, browser extensions, and other services available through this website, its sub-domains and our mobile application (collectively, the “Services”).

When we refer to “Personal Information” in this Policy, we mean information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual. Please note, as used in this Policy, “Personal Information” does not include information that has been deidentified or aggregated in a way that cannot be used to identify a specific individual.

You can access and interact with our Services in many ways, including from a computer or mobile device. This Policy applies regardless of how you access or interact with our Service. Depending on how you interact with our Service, there may be some cases where we need to provide you with additional information about how we use your Personal Information and/or what options you have regarding our use of your Personal Information. We may provide this additional information via notices our Service or via direct communications with you. If we do this, unless we tell you otherwise, the additional information will apply in addition to what is described in this Policy.

Please read this Policy carefully – it provides information about how we collect, use, and disclose your Personal Information in connection with our Service. If you do not want us to collect, use, or disclose your Personal Information in the ways described in this Policy, please do not use our Service, provide us with your Personal Information, or authorize a third party to make your Personal Information available to us. By using our Service, providing us with your Personal Information, or otherwise making your Personal Information available to us, you acknowledge that you understand that we may use your Personal Information as described in this Policy. If you have any questions about how we collect, use, protect, disclose, or otherwise process Personal Information, please contact us at security@impactbiosystems.com.

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PERSONAL INFORMATION WE COLLECT

Our primary goals in collecting Personal Information are to provide and improve our Service, to conduct our operations, to communicate with you and to enable users of our Service to enjoy and easily navigate it. This section describes what Personal Information we collect.
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Categories of Personal Information We Collect

Depending on how you access and use our Service, we may collect and disclose the categories of Personal Information listed below in connection with our Service and our business operations. Please note, depending on how you interact with us, we may not collect all (or any) of the Personal Information identified below.

• Identifiers and contact information, such as your real name, alias, physical address, email address, IP address, device information, and similar information.
• Biometric information such as your age, weight, height, gender, and self-reported injuries.
• Online identifiers you use, such as your username, social media handles, and similar information.
• Service account information, such as your username, password, account activity, account preferences, crash reports, and similar information.
• Payment information needed to complete transactions, including payment card information or bank account number.
• Communications you send us, including customer support communications, form submissions, messages and other requests you make through the Service.
• Marketing information, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other information you or other third parties provide to us.

Device and Usage Information

We may collect information about the devices that access or interact with this Website, which may include:

• Device information, such as the IP address, general geographic location, operating system, browser type, language preferences, mobile phone number, device identifier, and other similar information associated with a computer or mobile device used to access or interact with the Service.
• Information about interactions with the Service, such as links that are clicked, pages or screens that are viewed, access and session times, interactions with emails we send, and other similar information associated with activities on the Service.
• Information about Internet and network activity, such as websites visited, search engine results, and similar information associated with a computer or mobile device that accesses or interacts with the Service.
• Information automatically collected by cookies and other technologies on the Service.
• Any other information that a computer or mobile device automatically sends whenever connected to a website or online application.

For more information about how we collect Device and Usage Information, please see the “How We Collect Usage Information” section below.

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HOW WE COLLECT PERSONAL INFORMATION

Directly from You

When you engage with us in connection with the Service, such as requesting information, creating an account, signing up to receive communications, communicating with us, or otherwise interacting with us, we may ask you to provide certain Personal Information. Some of the Personal Information we request may not be required, however, we will specifically indicate what Personal Information is required to engage in such activity.

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THIRD PARTY PERSONAL INFORMATION COLLECTION

Based on the nature of the Service, third parties may collect information from or about you through your use of the Service. This section describes the different categories of third parties that may collect information about you in connection with the Service.

We may obtain information (which may include Personal Information) about you from sources that are not us, including, but not limited to, the Internet, offline sources, social media platforms, advertising or marketing platforms, ad networks and analytics providers, and other public or commercial sources (collectively, “Third Party Services”). 

When you access the Service through certain Third Party Services, associate the Service or your activity on the Service with certain Third Party Services, or share our content via certain Third Party Services, you acknowledge and agree that you are authorizing us to collect, store, share, and use any content and information we receive from those Third Party Services about you in accordance with this Policy.
We may combine the content and information we receive from Third Party Services with any information that we obtain about you in connection with the Service or our operations. In some cases, you may be able to revoke our access to content and other information we receive from certain Third Party Services, by changing the appropriate settings for your account with the applicable Third Party Service.
We may obtain Personal Information about you from our business partners and our service providers. We may also obtain Personal Information about you from any third party on whose behalf you access and use the Service, other users of the Service, or others that refer you to us.
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Linked Third Party Content

Any links to other websites, applications or other third party content on the Service are not an endorsement, authorization, or representation that we are affiliated with that third party and we are not responsible for the content, privacy, and security policies and practices of any third party. We encourage you to read the privacy policies or statements applicable to any third party websites, applications or content you access.
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Other Users

Depending on how you interact with the Service, other users may collect information about you that is published or otherwise generally made available on the Service. All users of the Service are subject to our Terms of Use. While we place restrictions on what our users are allowed to do with information made available to them on the Service, we are not responsible for any misuse of any information, including your Personal Information, by any user. If you believe that another user has misused your Personal Information or any other information available on the Service, please contact us at security@impactbiosystems.com.

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Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

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Do Not Track Signals

Please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments and legal changes.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please do so through the mobile App or contact us.

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HOW WE USE YOUR PERSONAL INFORMATION

We use Personal Information we collect for various purposes in connection with the Service and our operations. This section describes the purposes for which we use the Personal Information we collect.

Operational Uses

We may use your Personal Information for the following purposes:

• for any purpose with your consent and/or to fulfill any other purpose for which you provide your Personal Information or otherwise specify;
• to present the Service and/or changes and updates to the Service;
• to understand and analyze usage trends and user preferences;
• to notify you about changes to the Service;
• to present content to you and other users to fulfill our business purposes;
• to provide you with information that you request or that may be of interest to you;
• to provide customer service, including to respond to your comments or questions;
• to facilitate your use of the features you elect to use on the Service, including, without limitation, engaging in transactions with other users through the Service;
• to notify you about issues with, or changes to, our policies, terms, and agreements;
• to provide information about your access and use of the Service with any third party on whose behalf you interact with the Service;
• to enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in.

Marketing and Advertising

We, our service providers and our third party advertising partners may collect and use your Personal Information for marketing and advertising purposes:

• to promote the Service or to provide other promotions and services to you. In addition, we may share your Personal Information with our third party marketing partners for such their own use. If you do not wish to receive these communications (which may occur via email), you may opt out by using one or more of the options described in the “Managing Your Personal Information” section below;
• to display and target advertisements, marketing, promotions and content via the Service and in connection with any Third Party Services. For more information, please see the “Targeted Advertising” section below.

Compliance and Protection

We may use your personal information to:

• carry out our obligations and to enforce our rights arising from any contracts we have entered into, including, but not limited to, any such contracts between you and us;
• provide information to certain trusted representatives, advisors, business partners and corporate affiliates for certain purposes, including, but not limited to, information needed for such parties to provide services and support through the Service, enhance your experience on the Service, operate the Service and to facilitate transactions you engage in with other users.

Research & Development

We may use your Personal Information for research and development purposes, including to analyze and improve the Service and our business.
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Anonymous or De-Identified Data

We may use your Personal Information to create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your Personal Information and other individuals whose Personal Information we collect.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your Personal Information, such as when required by law.

Retention. We generally retain Personal Information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for Personal Information, we may consider factors such as the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the Personal Information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

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HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.
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Service Providers
Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).

Payment Processors
Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy https://stripe.com/privacy.

Sale of our Business; Bankruptcy
In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, we may transfer or allow third parties to use information owned or controlled by us, including Personal Information. We reserve the right, in connection with these types of transactions, to transfer or assign your Personal Information and other information we have collected to third parties and to authorize such third parties to use any such information. Except as ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Information will be subject to this Policy. However, any Personal Information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
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Compliance and Protection
We reserve the right to preserve and disclose any information, including Personal Information, that we believe is necessary to: (a) comply with any court order, law or legal process, including to respond to any government or regulatory request; (b) enforce or apply our Terms of Use (available at www.thepact.com/terms-conditions) and other agreements; and/or (c) protect the rights, property or safety of Impact Biosystems, our employees, our users, and others; (d) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
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Targeted Advertising
We may share Personal Information collected through cookies and other tracking technologies to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and our third party marketing partners, on and off the Service. You may opt out by using one or more of the options described in the “Managing Your Personal Information” section below.
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Professional Advisors
Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
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Use of Anonymized and Other Non-Identifying Information
We may share aggregated information about the uses and performance of the Service, and information that does not identify any individual, without restriction.

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MANAGING YOUR PERSONAL INFORMATION

We offer you several choices with respect to how we use your Personal Information. This section describes the mechanisms available to you to control the Personal Information we use about you in connection with the Service.
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Tools to Contact Us
If you want to update any Personal Information you have provided to us, update your preferences, control communications we send you, or otherwise contact us about your Personal Information, please email us at security@impactbiosystems.com.
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Additional Tools for Communications
For email communications you receive from us, you may opt-out of receiving such communications by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional emails from us. Please note, opting out of email communications will only apply to marketing and other promotional emails and will not apply to any email or other communications sent for non-marketing purposes, including, but not limited to, emails and other communications about your orders and other interactions with the Service.
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Targeted Advertising
If you do not want us to use Personal Information that we collect, or that you provide, to deliver advertisements according to our or our third party marketing partners’ target audience preferences, you can opt-out by sending us an email with your request to security@impactbiosystems.com. We do not control third parties’ collection or use of your Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your Personal Information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, located at https://www.networkadvertising.org.

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Choosing not to provide information. You may choose not to provide some of the Personal Information described above. Please note, however, that to use certain features of the Service, some Personal Information may be required to operate, so if you choose not to provide the Personal Information necessary to operate and provide you with a particular feature of the Service, you may not be able to use that feature.

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SECURITY OF YOUR PERSONAL INFORMATION

We are committed to protecting the security of your Personal Information. We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Information we collect and use in connection with the Service. Nevertheless, when disclosing Personal Information, you should remain mindful that there is an inherent risk in the use of email and the Internet. Your Personal Information and other information may be intercepted without our knowledge or consent, collected illegally and/or used by third parties that are not affiliated with and/or controlled by us. We cannot guarantee the security of any information, including your Personal Information, that you disclose online, and you do so at your own risk.

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CHILDREN’S PRIVACY
Our Service is not intended for anyone under 18 years of age. We do not knowingly collect or allow the collection of Personal Information in connection with the Service from anyone under the age of 13. If we learn that we have collected the Personal Information of anyone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information to us, you may contact us at security@impactbiosystems.com and ask us to remove your child’s Personal Information from our systems.
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INTERNATIONAL TRANSFERS

The Service is hosted in the United States and is only intended for individuals located in the United States. Personal Information collected through the Service is stored and processed in the United States. If you access or use the Service from outside the United States, you expressly consent to any transfer of Personal Information outside of your country to the United States which may not provide the same level of protection of your Personal Information as the laws in your country.

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CALIFORNIA PRIVACY RIGHTS
Under California’s Shine the Light Law, you have the right, once per calendar year, to request information from us regarding the manner in which we share certain categories of Personal Information with third parties for their direct marketing purposes, in addition to other rights described in this Policy. Under California’s Shine the Light Law, you have the right to send us a request at the email address designated below to receive the following information:

• the categories of Personal Information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
• the names and addresses of the third parties that received the information; and
• if the nature of the third party’s business cannot be determined from their name, examples of the products or services they market.

This information may be provided in a standardized form that is not specific to you. The designated email address for these requests is security@impactbiosystems.com.

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UPDATES TO THIS POLICY
From time to time, we may revise this Policy to reflect changes in the Service and/or our operations or to ensure that this Policy complies with applicable laws. Consequently, we reserve the right to update and revise this Policy at any time in our sole discretion. If we make material changes to this Policy, we will notify you by updating the date of this Policy and posting it on the Service or other appropriate means. Any modifications to this Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Policy. Your continued use of our Service indicates your acknowledging that the modified Policy applies to your interactions with the Service and our business. We recommend that you review this Policy regularly to ensure that you are aware of its terms. You will know if this Policy has been revised since your prior visit by referring to the Last Updated Date at the top of this page.

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HOW TO CONTACT US
We welcome your questions, comments, and concerns about privacy. Please email us at security@impactbiosystems.com with any questions or feedback you have pertaining to our privacy practices.