Lifesci Advisors, LLC
Updated April 1, 2022
1. THIS POLICY
2. PERSONAL INFORMATION
In order to serve your needs, process account transactions, and fulfill legal and regulatory requirements, LifeSci collects certain information, including but not limited to the following:
- Information Provided by You: Information provided to us and our affiliates by you (such as on account applications and related forms, via contact with our employees and representatives, through our website, or through use of our services).
- Information Related to You: Information gathered from our internal files regarding your transaction history with us (such as products or services purchased, account balances, trading history, and payment history), information you manifestly chose to make public (e.g., information from your social media or business networking profile(s)), as well as that provided by information service companies and consumer reporting agencies (such as transactions or credit relationships with unaffiliated third parties). We also may collect information obtained in the ordinary course of our relationship with you (e.g., we provide a service to you or your employer, or you visit our offices).
- Third Party Information: Information provided by other unaffiliated third parties, including employers, associations, retirement plan benefit sponsors, and other institutions, if the customer transfers positions or funds to
For purposes of this policy, this information may be referred to as “personal information.” Personal information also includes, but is not limited to, information about an individual, or from which an individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.
“Personal information” may include “nonpublic, personal information,” which means information that is not readily known or accessible in the public realm, such as your social security number, birth date, net worth, assets, income, and medical information (if applying for insurance), as well as the fact that you have an account with us.
We (or our service providers acting on our behalf) may collect personal information about your use of this website or participation in online events organized by LifeSci. This may include information that may identify you as well as statistical or aggregate information that does not identify you. In addition, web log information is automatically gathered every time you visit the website. It gathers nonpersonal identifying information such as Internet browser type, IP address, date and time stamps associated with transactions, and the pages you visited (see the use of “cookies” below).
We also may create personal information about you including, but not limited to, records of your interactions with us, our clients, other customers, visitors, and third-party affiliates.
Where LifeSci needs to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you. In such cases, we may have to cancel a product or service you have with us, but will notify you if this is the case at the time.
3. USE AND DISCLOSURE OF INFORMATION
Use of Information
We may use and process the following categories of your personal information:
- Personal details: such as given name(s), preferred name, contact information, personal credentials, demographic information (such as date of birth, salutation, title, and language preferences), and photograph (if provided).
- Account information: such as your username, password, privacy preferences, and account setting preferences.
- Metadata: Metadata that is automatically generated by our systems in the regular course of your usage of LifeSci’s website and products.
- Views and opinions: any views and opinions that you choose to send to us, or publicly make available about us on social or public platforms.
- Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
- Payment details: invoice records; payment records; billing address; payment method; bank account number; card or account security details; payment amount; and payment date.
- LifeSci communications: records of communications and feedback that you have shared with LifeSci and its affiliates.
- Service-related communications: information about communications during your engagement with LifeSci or inquiry about its services, including the contents and logs of any of your communications, the time and duration of such communications, and other information defining such communications (e.g., device type).
Legal Basis for Processing Personal Information
We may rely on one or more of the following legal bases in processing your personal information for the purposes outlined in this policy:
- Consent: We may process your personal information where we have obtained your prior, express consent (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
- Contractual necessity: We may process your personal information where the processing is necessary in connection with any contract that you may enter into with us.
- Compliance with applicable law: We may process your personal information where the processing is required by applicable law or fulfilling our health and safety obligations to employees.
- Vital interests: We may process your personal information where the processing is necessary to protect the vital interests of any individual.
- Legitimate interests: We may process your personal information where we have a legitimate interest in the processing. A legitimate interest can be understood to exist when (a) we have ensured that the processing is lawful, proportionate, and conducted in accordance with the terms of this policy; (b) we have ensured that we have a legitimate business need to perform the processing; and (c) we have ensured that there is no material likelihood of any disproportionate adverse impact on your interests, or adverse impact on your fundamental rights or freedoms, as a result of the processing.
Purposes for Which We May Process Personal Information
We may process your personal information for the following purposes:
- Improving user experience: LifeSci and its clients are able to access surveys, transcripts, online event participation and other records.
- Knowledge building and analysis: LifeSci analyzes registrations for online events to optimize it services.
- Service improvements and analytics: Administering, facilitating, processing, and/or tracking your use of LifeSci’s services, including without limitation for analytical and training purposes so that we can improve, support, operate, and develop LifeSci’s services for you.
- Communications: Communicating with you via any means (including email, phone/voice call, text message, instant message, fax message, social media, postal mail, and/or in-person) for purposes of administering or managing your use of LifeSci’s services, or providing information in which you may be interested (e.g., upcoming LifeSci events, new product offerings, or information relevant to you), subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate.
- Communications and IT operations: management of our communications systems; operation of IT security systems; and IT security audits.
- Improving our site and services: identifying issues with our sites, or our services; planning improvements to our sites, or our services; and creating new sites, or services.
- Security: physical security of our premises (including records of visits to our premises; and surveillance recordings); and electronic security (including login records and access details).
- Storage and backup: storing, backing up (whether for disaster recovery or otherwise) of your personal information on LifeSci’s servers.
- Financial management: sales; finance; corporate audit; and vendor management.
- Legal proceedings: establishing, exercising, and defending legal rights.
- Legal compliance: compliance with our legal and regulatory obligations under applicable law (including fulfilling our health and safety obligations to employees).
- Marketing: for marketing purposes, if you have separately consented to it.
- Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.
Disclosure of Information
Pursuant to federal law, we may not disclose your personal information without your prior consent, unless the disclosure is needed to:
- provide the services requested by you or one of your appointed representatives;
- provide you with marketing materials regarding our products and/or services, as well as those offered pursuant to joint agreements with our affiliates or non-affiliated third parties, so long as all parties offering the products and/or services have agreed, in writing, to protect the confidentiality of your information and to not use it for any other purpose;
- process your information (including through our processors, other third party processors, and any third party providers of advertising, plugins, or content used on our site) for legitimate business purposes;
- enforce any of our rights, including the collection of any fees or other payments due;
- provide any of LifeSci’s affiliates with information regarding our operations, or as reasonably required pursuant to the proposed or actual sale, merger, transfer, or exchange of all, or a portion of, our business;
- comply with accountants, auditors, lawyers, and other outside professional advisors to LifeSci, subject to binding contractual obligations of confidentiality;
- respond to what we believe is potential physical, financial, or other harm, injury, or loss;
- comply with the request or requirements of regulatory and/or law enforcement organizations;
- respond to a subpoena or discovery request; or
- provide disclosures as otherwise permitted or required by law.
We may provide such information to LifeSci’s affiliates and/or unaffiliated financial or non-financial services providers (such as insurance companies, mutual fund companies, banks, investment firms, third-party administrators, clearing firms, accountants, auditors, lawyers, professional advisors, and other third parties who assist us in providing account maintenance or customer service) as necessary pursuant to the exceptions listed above.
If we engage a third-party processor to process your personal information, the processor will be subject to binding contractual obligations to: (i) only process the personal information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the personal information; together with any additional requirements under applicable law.
We do not sell, share, or disclose your nonpublic personal information to unaffiliated third-party marketing companies.
International Transfer of Personal Information
Sensitive Personal Information
Unless required by law, we do not and will not collect or process any of the following types of sensitive information without your consent:
- Race or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Trade union memberships
- Genetic or biometric information
- Health or mortality
- Sex life or sexual orientation
Where it becomes necessary to process your sensitive personal information for any reason, we rely on one of the following legal bases:
- Compliance with applicable law: We may process your sensitive personal information where the processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
- Detection and prevention of crime: We may process your sensitive personal information whether the processing is necessary for the detection or prevention of crime (including the prevention of fraud);
- Establishment, exercise, or defense of legal rights: We may process your sensitive personal information where the processing is necessary for the establishment, exercise, or defense of legal rights; or
- Consent: We may process your sensitive personal information where we have, in accordance with applicable law, obtained your prior, express consent prior to processing your sensitive personal information (this legal basis is not used in relation to processing that is in any way necessary or obligatory).
If you provide sensitive personal information to us, you are responsible for ensuring that it is lawful for you to disclose such information to us, including ensuring that one of the legal bases set out above is available to us with respect to the processing of that sensitive personal information.
#. OPTING OUT
Subject to any undertakings set forth in any terms or client service contract to which you are party, you may request that we not disclose your personal information for any reason - other than one of the exceptions listed above (see “Use and Disclosure of Information” above). We will process your request within a reasonable time and, unless the request concerns an exception listed above or law permits us to, will thereafter not collect, use, and/or disclose your personal information in the manner stated in your request.
To request that we not disclose your information for this or any purpose (other than those covered under the exceptions listed under “Use and Disclosure of Information”), please email us at email@example.com. If we do not receive such a request from you within thirty (30) days of you opening an account, contracting for services, or receiving our annual privacy notice, we have the right to assume you do not object to the disclosure of your information for any reason permitted by federal law until you notify us to the contrary. (Please note that the laws of certain states may impose additional restrictions upon the disclosure of customers’ confidential information.)
Please note that under certain circumstances your withdrawal of consent could result in us being unable to provide you certain services.
#. INFORMATION ACCURACY
We take reasonable steps to ensure that your personal information is kept accurate and up-to-date and is erased or rectified if we become aware of inaccuracies. From time to time, we may ask you to confirm the accuracy of your personal information.
#. INFORMATION MINIMIZATION
We take reasonable steps to ensure that your personal information that we process is limited to the personal information reasonably necessary in connection with the purposes set out in this policy.
#. INFORMATION RETENTION
LifeSci takes reasonable steps to ensure your personal information is only stored for the time necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Additionally, LifeSci reserves the right to delete any account and the personal information associated with a user that does not comply with our use of service requirements.
To determine the appropriate retention period for personal information, we will consider the amount, nature, and sensitivity of 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, whether we can achieve those purposes through other means, and the risk of your information being the subject of any relevant legal claims.
Once none of these periods are in effect, we will either (a) permanently delete or destroy the relevant personal information, or (b) anonymize the relevant personal information. We will also instruct any third-parties with whom we have shared it to do the same within a reasonable period of time after such periods expire.
#. YOUR LEGAL RIGHTS
Subject to applicable law, you may have a number of rights regarding the processing of your relevant personal information, including:
- the right not to provide your personal information to us (but note that we may be unable to provide you with the full benefit of our services and site[s] if you do not provide us with your personal information);
- the right to request access to, or copies of, your relevant personal information, together with information regarding the nature, processing, and disclosure of those relevant personal information;
- the right to request correction of any inaccuracies in your relevant personal information;
- the right to request, on legitimate grounds:
- erasure of your relevant personal information; or
- restriction of processing of your relevant personal information;
- the right to object, on legitimate grounds, to the processing of your relevant personal information by us or on our behalf;
- the right to have certain relevant personal information transferred to another controller, in a structured, commonly-used, and machine-readable format, to the extent applicable;
- where we process your relevant personal information on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we process notice of such withdrawal, and does not prevent the processing of your personal information in reliance upon any other available legal bases); and
- the right to lodge complaints regarding the processing of your relevant personal information with a data protection authority.
To make use of any of these rights, we may require information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. You will not have to pay a fee to access your personal information (or to exercise any of these other rights).
#. SAFEGUARDS TO PROTECT PRIVACY
LifeSci takes precautions to protect your information. We maintain physical, electronic and procedural safeguards in an effort to secure your information. Only those employees and agents who need to know that information to provide services to you are granted access to personal information. Although LifeSci security measures conform to those of the industry, LifeSci makes no claim or warranty as to the security or impenetrability of LifeSci’s system under unusual circumstances or its resilience to future sophisticated attacks. Please keep LifeSci’s service secure by keeping your credentials and all LifeSci account details confidential.
We have procedures to deal with any suspected personal information or data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
#. COOKIES AND SIMILAR TECHNOLOGIES
A cookie is a small text file placed in your computer’s browser to store your preferences. A cookie can be accessed only by the server that originally created the cookie. A cookie cannot store or send back any information to us that you have not specifically and voluntarily provided while on a Site, or that is not among the information that is contained in every user’s browser (e.g., domain name, browser type). Cookies do not contain personally identifiable information; however, once you choose to furnish a site with personally identifiable information, this information may be linked to the data stored in the cookie.
#. COMMUNICATIONS AND DIRECT MARKETING
LifeSci may occasionally send you communications. Communications regarding your user information may be sent to your email. LifeSci may also reach your email for editorial, account maintenance, administrative, security-related, and marketing purposes. LifeSci may contact you about our marketing partners’ products with your consent or as permitted by law.
You may choose not to receive LifeSci marketing communications by clicking on the unsubscribe link in the emails you receive from us. Please note that even if you opt out of marketing emails, LifeSci may continue to send other types of communications.
#. PRIVACY PRACTICES OF THIRD PARTIES
LifeSci’s sites and services are not directed towards anyone under the age of 18. If a parent or guardian becomes aware that their child is interacting with LifeSci or providing us personal information, please contact us immediately. If we discover at any point that a child under the age of 18 is using our services, we will terminate their account immediately.
C. Relation to Other Agreements