Privacy Policy

Talis Biomedical Corporation Privacy Policy

Effective: 30 April 2021

This website is directed to consumers and individuals located in the United States.

This Privacy Policy (the “Policy) explains how Talis handles personal information that we collect online, through our websites and through our offline interactions with you (collectively, the “Talis Services”). This Privacy Policy does not apply to information collected from residents of countries in the European Economic Area, or to third-party websites to which Talis may link. Your use of Talis Services which link to this Privacy Policy are subject to this Privacy Policy and the Terms of Use.

Please read this Privacy Policy before using the Talis Services or submitting personal information to us. By using the Talis Services, you accept and expressly agree to our practices surrounding the collection, use, and sharing of personal information provided by you in the manner described in this Privacy Policy.  If you do not agree with the terms of this Privacy Policy, you cannot, and we do not authorize you to, access, browse, or use the Talis Services.

On occasion, Talis may offer apps, special programs, activities, events or promotions (“Programs”) that have unique or additional specific terms, privacy notices and/or consent forms that explain how any information you provide will be processed in connection with the Programs. You should review the applicable terms before interacting or participating in the Programs.

PERSONAL INFORMATION
“Personal information” is information that identifies you as an individual or relates to an identifiable individual. Examples of personal information include your name, your email address, your postal address and your telephone number.

HOW DOES TALIS COLLECT PERSONAL INFORMATION?
In the past twelve (12) months, Talis has collected personal information in a few different ways:

  • Information you voluntarily submit or choose to provide
  • Information you give us permission to collect from you or another source
  • From Health Care Professionals
  • Through our website
  • From contract research organizations and clinical trial investigators
  • From your participation in Talis programs or clinical trials
  • From third party service providers and business partners
  • Automatically from devices you use to connect to Talis Services (See “Cookies and Other Tools” below)
  • Information provided by Talis partners
  • From public sources including, but not limited to, social media and other websites that enable social sharing
  • Information from government agencies, public or third-party information sources

We may also combine information we get from a third-party with information we already have, and we may combine information that we have collected offline with information we collect online.

If you choose to submit any personal information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy.

INFORMATION TALIS COLLECTS
In the past twelve (12) months, Talis has collected the following categories of personal information:

  • Contact information and preferences (such as name, email address, mailing address, phone number, and emergency contact information)
  • Biographical and demographic information (such as date of birth, age, gender, ethnicity, marital status, and sexual orientation)
  • We may collect certain health and medical information in connection with managing clinical trials, conducting research, distributing and marketing our products, and tracking adverse event reports
  • Payment-related information we need to complete a transaction (such as credit card number and financial account information)
  • Username and password that you may select in connection with establishing an account on our websites
  • Your photograph, social media handle or digital or electronic signature
  • Publicly available information
  • Internet activity, such as your Internet Protocol (“IP”) address, browsing history, your search history and information on your interaction with the Talis Services and our advertisements
  • Device information
  • Geolocation data, e.g., your physical location or movements (See “Cookies and Other Tools” below)
  • Inferences drawn from other personal information listed above, to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes
  • If you are accessing Talis websites on your mobile device, you may also choose to provide us with location data. To protect your privacy, you should not provide Talis with any information that is not specifically requested
  • Any adverse event information

If you are a Health Care Professional, we may also collect:

  • Professional credentials, educational and professional history, institutional and government affiliations, information included on a resume or curriculum vitae, education and work history (such as work experience, education and languages spoken)
  • Information about the Talis programs, products and activities with which you have engaged
  • Details about our interactions with you, your prescribing of our products and the agreements you have executed with us, including remittance or other financial information
  • Any information you choose to provide about yourself or your household
  • Information collected in connection with Talis hosted events or activities you attend or participate in
  • Publicly-available information related to your practice, such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence related information

We may use the personal information we collect about you with information obtained from other sources, such as public databases, social media platforms and other third parties. For example, we may use public information to confirm contact or financial information, to verify licensure of Health Care Professionals or to better understand your interests by associating demographic information with the information you have provided.

HOW DOES TALIS USE PERSONAL INFORMATION?
How Talis uses your information depends on how you interact with the Talis Services.  In the past twelve (12) months, Talis has disclosed the following categories of personal information to:

  • Provide our products and services to you and make them better
  • Develop new products and services
  • Fulfill your requests
  • Provide customer service
  • Send you administrative communications regarding Talis’s products or Talis Services
  • Notify you about special promotions or offers that may be of interest to you
  • Invite you to participate in surveys about our products or services
  • Better understand the interests of our customers and visitors who use Talis Services
  • Maintain Talis’s online services such as our websites
  • Monitor, detect and prevent fraud, improper activity and ensure Talis’s policy compliance
  • Conduct research including secondary and follow-on research
  • Determine an individual’s eligibility to participate in Talis programs or clinical trials
  • Process payments
  • Evaluate how you and other users interact with our online services
  • Protect Talis and our users
  • Secure our online services including our network and websites
  • Conduct audits related to our current interactions with you
  • Debug the site and service to identify and repair errors that impair existing intended functionality
  • Defend ourselves in litigation and investigations and to prosecute litigation
  • Comply with our legal and regulatory obligations

Talis may also use information collected from you or about you to offer you customized content, including to:

  • Recognize new or past visitors to our websites
  • Remember your personal preferences
  • Show you more relevant and meaningful advertisements based on your interests

Talis may also use your personal information for other purposes disclosed to you from time to time.

In addition, some of our mobile-optimized sites may have location-based features. To deliver these features, we may collect and use location data provided by your mobile device. By using such applications, you consent to the collection and use of your mobile device location data for purposes of delivering these location-based features.

We may use personal information collected from any of the sources listed in the “How Does Talis Collect Personal Information?” section of this policy for our internal business purposes, such as data analysis, audits, developing new products, enhancing our websites, improving Talis Services, identifying usage trends and determining the effectiveness of our promotional campaigns.

We may aggregate and/or de-identify data about customers and site visitors and use it for any purpose, including product and service development and improvement activities.

DOES TALIS SHARE PERSONAL INFORMATION?

We do not sell your personal information. However, we share personal information with our vendors, contractors, business and service partners, or other third parties (collectively, “Service Providers”). Examples of Service Providers include analysis firms, advertisers, payment processing companies, customer service and support providers, email, IT services and SMS vendors, web hosting and development companies and fulfillment companies. Service Providers also include our co-promotion partners for products that we jointly develop and/or market with other companies.

Some Service Providers may collect personal data on behalf of Talis. These third parties may be provided with access to personal data needed to perform their functions. In addition, Talis’s practice is to require its Service Providers to keep your personal information confidential and to use personal information only to perform functions for Talis.

If Talis sells all or part of one of its product lines or divisions, your information may be transferred to the buyer. Talis reserves the right to disclose your information to respond to authorized information requests from government authorities, to respond to valid judicial requests, to address national security situations, to provide security and investigate potential fraud, or when otherwise required by applicable law.

Talis may also disclose your personal information as required by law to any competent law enforcement body, regulatory or government agency, court or other third party where we believe the disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request or legal process served on us, or to protect the safety, rights, or property of our customers, the public, Talis or others, and to exercise, establish or defend Talis’s legal rights.

Talis may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose.

Cookies and Other Tools

Talis and its Service Providers collect information about you by using cookies, tracking pixels, web beacons and other technologies (collectively, “Tools”). We use this information to better understand, customize and improve user experience with our websites, services and offerings as well as to manage our advertising. This information can make your use of our Talis Services easier and more meaningful by allowing Talis and our Service Providers to provide better service, customize sites based on consumer preferences, compile statistics, provide you with more relevant advertisements based on your interests, analyze trends and otherwise administer and improve our Talis Services. If we have collected your personal information, we may associate this personal data with information gathered through the Tools.

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org.

You can also control Flash cookies which we may use on certain Talis websites from time to time by clicking here. Why? Because Flash cookies cannot be controlled through your browser settings. Choices you make are both browser and device specific.

Here are some of the types of information collected when visiting Talis websites:

Log data: When you use Talis websites, our servers automatically record information (“log data”), including information that your browser sends whenever you visit an website or app or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the webpages you visited that had Talis features, browser type and settings, the date and time of your request, how you used websites and cookie data.

Cookie data: Depending on how you are accessing Talis’s online Services, we and our Service Providers may use “cookies” (a small text file sent by your computer each time you visit our sites, unique to your Talis account or your browser) or similar technologies, to record log data. When we use cookies, we may use “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you and/or your browser delete them). For example, we may use cookies to remember your personal preferences, such as sections of the website that you visit frequently, your user ID, or other settings so you do not have to set them up every time you visit, and we may use cookies to serve you relevant advertising tailored to your interests. Some of the cookies we use are associated with your Talis account (including personal information about you, such as the email address you gave us), and other cookies are not.

We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Talis Services and report on activities and trends. This service may also collect information regarding the use of other websites and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy/google-partners, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Social media plugins and data. In addition, our websites may use social media plugins (e.g., the Facebook “Like” button, ‘”Share to Twitter”‘ button) to enable you to easily share information with others. When you visit any of our online Talis Services, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our websites. If you are logged into the social media website (e.g., Facebook, Twitter, Google+) while browsing on our Talis Services, the social plugins allow that social media website to receive information that you have visited our Talis Services. The social plugins also allow the social media website to share information about your activities on Talis with other users of their social media website. Talis does not control any of the content from the social plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.

If you choose to link your social media or Google account to Talis, this allows us to obtain information from those accounts (such as your friends or contacts). The information we obtain from these services often depends on your settings or the applicable provider’s privacy policies, so please check these policies before granting us access. You agree that we are not responsible for any acts or omissions by these social media service providers. If you give us permission to access this information, we will use it for the purposes described in this Privacy Policy.

Device information. In addition to log data, we may also collect information about the device you are using to access our Talis Services, including what type of device it is, what operating system you are using, device settings, unique device identifiers and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. For example, different types of information are available depending on whether you are using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device may make available to us, please also check the policies of your device manufacturer or software provider.

Interest Based Advertising. Talis hopes to deliver to you advertising for products and services you need or want.  Talis, its vendors and partners, use common tracking tools, such as cookies, pixels, web beacons, and similar technologies, to automatically collect information about users for purposes of enhancing their online experience and delivering more meaningful advertisements. Like many companies, Talis may also utilize third-party advertising vendors and other partners to collect this information.

Like most companies, we place advertisements where we think they will be most relevant to customers. One way we do so is by allowing network advertising companies with whom we work to place their own Tools when an individual visits Talis websites. This enables the network advertising company to recognize individuals who have previously visited Talis websites and to serve you ads based on your web browsing activity, purchases, interests and/or other information—a practice commonly referred to as interest-based advertising (“IBA”) or online behavioral advertising (“OBA”).

These advertising companies may also use these types of technologies to recognize you across the devices you use, such as a mobile phone or a laptop, and serve you ads on websites you visit and applications you use.

Retargeting.  One way in which we deliver more meaningful advertisements is through a common form of online advertising known as “retargeting” or “remarketing.” Retargeting works by serving ads on one site based on an individual’s online activities on a different, unrelated site. For example, if you look at Talis One products on a Talis website, you may later see an advertisement for Talis One products when you visit third-party sites. To do this, Talis or its advertising vendors may use a device ID, cookie, pixel, web beacon or similar technology placed by Talis or our third-party vendor when you visit Talis websites third-party websites or apps. The placing of these cookies or other technologies on your device may enable you to be identified across multiple websites. You should consult the privacy policies of our vendors and other websites that you visit to understand how they collect and use your data.

WHAT CHOICES DO I HAVE ABOUT HOW TALIS COLLECTS AND USES INFORMATION ABOUT ME?
Certain Talis Services may ask whether you wish to opt-out or opt into our contact lists for offers, promotions and additional services that may be of interest to you.

Marketing

If you no longer wish to receive promotional marketing materials from us on a going-forward basis, you may opt-out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from Talis by following the instructions included in the email. We will endeavor to comply with your request as soon as reasonably practicable.

However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our Privacy Policy or Terms of Use).

Your Privacy Choices

You may have certain rights and choices regarding our processing of your personal data.  Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right (with certain limitations and exceptions) to:

  • Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared
  • Access a copy of the personal information we retain about you
  • Request deletion of your personal information

The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their personal information.  This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months.  You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; and
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise the access, data portability, opt out, and deletion rights described above, please submit a verifiable consumer request to us in one of the following ways:

  • By Mail: Attn: Legal Department, 230 Constitution Drive, Menlo Park, CA 94025
  • By Email:  privacy@talisbio.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  If you are an authorized agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identify. Where we deny your request in whole or in part, we will endeavor to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

We will not restrict or deny you access to our Talis Services because of choices and requests you make in connection with your personal information. Please note, certain choices may affect our ability to deliver the Talis Services. For example, if you sign up to receive marketing communications by email, then ask Talis to delete all your information, we will be unable to send you marketing communications. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days after its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

HOW DOES TALIS SECURE INFORMATION?
It is Talis’s practice to take steps to secure our Talis Services; however, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your health. Talis cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to Talis websites, you must weigh both the benefits and the risks. Talis websites may link to third-party websites that are not controlled by Talis or subject to a Talis privacy policy. You should check the privacy policies of such third-party websites before submitting personal information.

THIS WEBSITE IS NOT FOR CHILDREN
Talis does not knowingly collect or use any information from children (we define “children” as minors younger than 13). We do not knowingly allow children to order our products, communicate with us, or use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below and we will work with you to address this issue.

THIRD PARTY SITES
We may provide links to websites and other third-party content that is not owned or operated by Talis. The websites and third-party content to which we link may have separate privacy notices or policies. Talis is not responsible for the privacy practices of any entity that it does not own or control.

If you provide any personal information through a third-party site, your interaction and your personal information will be collected by, and controlled by the privacy policy of, that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this privacy policy.

CROSS BORDER TRANSFERS
Any information you provide to Talis may be stored and processed, transferred between and accessed from the United States, where Talis is headquartered, and other countries which may not guarantee the same level of protection of personal data as the one in which you reside. However, Talis will handle your personal data in accordance with this privacy policy regardless of where your personal data is stored/accessed.

HOW CAN I CONTACT TALIS?
If you have questions about your information, please contact us by clicking on the “Contact Us” link on the website you are visiting or by e-mailing us at privacy@talisbio.com. Alternatively, you may send a letter to the following address:

Talis Biomedical Corporation
Attention: Legal Department
230 Constitution Drive

Menlo Park, CA 94025

In all communications to Talis, please include the email address used for registration (if applicable), the website address or the specific Talis program to which you provided personal information (e.g. Talisbio.com, etc.) and a detailed explanation of your request. We will do our best to respond to all reasonable requests in a timely manner.

HOW WILL I KNOW WHETHER TALIS HAS UPDATED THIS POLICY?
Talis reserves the right to amend this Privacy Policy at any time. If Talis changes its privacy practices, a new Privacy Policy will reflect those changes and the effective date of the revised Privacy Policy will be set forth in this paragraph. This Privacy Policy was last updated on (30 April 2021) and is effective as of that date.