Privacy Policy

Personal Information we collect

Information you provide to us or that we generate about you.  Personal information you may provide to us through the Service or otherwise or that we may generate about you includes:

• Contact data, such as your first and last name, salutation, email address, mailing address, professional title and company name, and phone number.
• Demographic Information, such as your city, state, country of residence, and postal code.
• Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Profile data, such as the username and password that you may set to establish an online account on the Service and any other information that you add to your account profile.  
• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
• Profile data, such as the username and password that you may set to establish an online account on the Service and any other information that you add to your account profile.  
• User-generated content data, such as comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata.  Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited.  Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• Payment data needed to complete transactions, including payment card information or bank account number.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Data providers, such as data licensors.
• Marketing partners, such as joint marketing partners and event co-sponsors.
• Linked third-party sources, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service such as Google that you use to log into, or otherwise link to, your Service account. This data may include your Google username, profile picture and other information associated with your Google account on that third-party service that is made available to us based on your account settings on that service. Our use and disclosure of information received from Google’s APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or general geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Chat technologies, such as those provided by OpenAI and Intercom that employ software code and other technologies to operate the chat features that you can use to communicate with us through the Service.  OpenAI, Intercom and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Privacy Policy.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery.  We may use your personal information to:

• provide, operate and improve the Service and our business;
• personalizing the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• providing chat or message functionality;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events in which you participate;
• 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; and
• provide support for the Service, and respond to your requests, questions and feedback.

Research and development.  We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing and advertising.  We, our service providers and our third-party partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms

Compliance and protection.  We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

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.  

Cookies and similar technologies. In addition to the other uses included in this section, we may use the c the following purposes:

• Technical operation. To allow the technical operation of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails.

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.

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, online chat functionality providers, email delivery, consumer research, 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.

Advertising partners.  Third-party advertising companies for the interest-based advertising purposes described above.

Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested.

Business and marketing partners. Third parties with whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you.

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.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees.  Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in Synthesize Bio (including, in connection with a bankruptcy or similar proceedings).  

Your Choices

In this section, we describe the choices available to you.

Opt-out of marketing communications.  You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.  Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Advertising choices.  You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

• Browser settings.  Changing your internet web browser settings to block third-party cookies.
• Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
• Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising.  You may be able to exercise that option at the following websites:
• Google: https://adssettings.google.com/ Facebook: https://www.facebook.com/about/ads
• Ad industry tools.  Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
• Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp Digital Advertising Alliance: optout.aboutads.info.   AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
• Mobile settings.  Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.  We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties.  In addition, our content may be integrated into web pages or other online services that are not associated with us.  These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party.  We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us.  If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy 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 Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us

Email privacy questions to privacy@synthesize.bio
Email security questions to security@synthesize.bio

Additional information for California residents

Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to privacy@synthesize.bio.  In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Additional information for EEA, UK, and other GDPR-covered users

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction where the General Data Protection Regulation or similar data protection laws apply, this section applies to you.

Controller / processor roles

For personal information we collect and process in connection with our website, marketing, and business operations, Synthesize Bio acts as the controller. When we process personal information on behalf of an enterprise customer while providing the Synthesize Bio platform or services, we act as a processor or service provider to that customer, and that customer’s privacy notice and instructions govern that processing. If you have questions about personal information that we process on behalf of a customer, please contact that customer first.

Our legal bases for processing

We process personal information only where we have a valid legal basis under applicable law, including:

• performance of a contract or steps taken at your request before entering into a contract;
• our legitimate interests, where those interests are not overridden by your rights and freedoms, such as operating and improving our services, securing our systems, preventing fraud, and communicating with users;
• consent, where required, including for certain marketing communications and cookies or similar technologies; and
• compliance with legal obligations.

Where required by law, we will explain the relevant legal basis at the time we collect the information.

Your rights

Subject to applicable law, you may have the right to:

• request access to the personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of your personal information;
• request restriction of processing;
• object to our processing of your personal information, including for direct marketing;
• request portability of your personal information; and
• withdraw consent where processing is based on consent.

If you would like to exercise any of these rights, please contact us using the details below. We may need to verify your identity before responding.

International transfers

We are based in the United States and may transfer personal information to the United States and other countries that may not provide the same level of data protection as your home country. Where required for transfers from the EEA, UK, or Switzerland, we use appropriate safeguards such as adequacy decisions or standard contractual clauses, together with any additional measures that may be required.

Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to meet legal, accounting, reporting, and dispute-resolution requirements. In determining retention periods, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information, and applicable legal requirements.

Automated decision-making

We do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects without providing notice and any rights required by applicable law.

Complaint rights

If you are located in the EEA or UK, you may also have the right to lodge a complaint with your local data protection authority or supervisory authority.

How to contact us

Email privacy questions to privacy@synthesize.bio
Email security questions to security@synthesize.bio

Data Protection Officer

We have appointed a Data Protection Officer (“DPO”). You may contact our DPO, Stein Setvik, at stein@synthesize.bio.