Last Updated: January 23, 2022

This privacy policy (the “Privacy Policy”) describes Breakthrough Biotech Law’s policy in connection with information that we collect online and offline through websites, software applications, social media, emails, or any other interactions you may have with us (collectively, the “Services”).

COLLECTION OF PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, such as your name, address, telephone number, email, or employment information.  Personal information may be collected through Services or from other sources such as publicly available databases or websites.

Personal information may need to be collected to provide the requested Services.  If you do not provide the information requested, we may not be able to provide the Services.  If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

USE OF PERSONAL INFORMATION

We and our service providers use Personal Information for legitimate business purposes.  We may use your personal information to provide you with the functionality of the Services, including arranging access to client portals, responding to your inquiries, or sending administrative information to you.  We may also use your Personal Information to provide you with marketing materials or with your permission to facilitate social sharing.  We may aggregate or anonymize your Personal Information so that it will no longer be considered Personal Information to generate other data for our use.  We may use your Personal Information for business purposes, for example, for data analysis, for audits to verify compliance, for fraud and security monitoring, to meet legal and/or regulatory obligations, for enhancing or improvising Services, for identifying usage trends, for determining effectiveness of our marketing, or for expanding our business activities.   We may also use your Personal Information to validate authorized signatures, to contact others in connection with providing the Services.

DISCLOSURE OF PERSONAL INFORMATION

We disclose Personal Information to third party service providers to facilitate services they provide to use, such as website hosting services, data analysis, information technology, email delivery, and auditing.  By using the Service, you may elect to disclose Personal Information, although any public disclosure may be available to other users and the general public.  We may disclose your Personal Information as necessary if we have a legal obligation or legitimate reason to do so to comply with applicable laws and regulations, to cooperate with governmental authorities, or in connection with a sale or business transaction.

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as browser and device information, App usage data, and demographic or aggregated information that does not disclose your identity.  If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

Other Information may be collected in a variety of ways, including through your browser or other devices, or through your IP address.  An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited.  Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services.  We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services.  We may also derive your approximate location from your IP address.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

USE OF COOKIES AND SIMILAR TECHNOLOGIES

Breakthrough Biotech Law may collect your device IP address, unique device ID, hardware and software type, Internet service provider, serving domain, geographical area, location data, browser type and settings data (such as screen resolution, color depth, time zone settings, browser extension and plugins) operating system, referring URLs, search history, information on actions taken or interaction with our digital assets (e.g., page views) and dates and times of actions through the use of cookies and similar technologies.  

The types of cookies we may collect are required cookies to enable you to navigate the Site and to use its services and features.  Without these absolutely necessary cookies, we may not be able to provide the Site or certain services or features.  We may also collect analytics cookies, which allow us to analyze your use of the Site to evaluate and improve outperformance, for example, by providing us with information about how our site is used.

Most web browsers allow you to manage cookies through the browser settings. Be aware that, if you opt out from and do not agree to certain cookies, your experience on our Services may be diminished and some features may not work as intended depending on the cookie. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org. 

If you want to clear all cookies left behind by the websites you have visited, here are links where you can download three programs that clean out tracking cookies:

http://www.lavasoftusa.com/products/ad-aware_se_personal.php

http://www.spybot.info/en/download/index.html

http://www.webroot.com/consumer/products/spysweeper/

SECURITY

Breakthrough Biotech Law uses reasonable organizational, technical, and administrative measures to prevent the unauthorized release of or access to Personal Information.  All information you provide to us is stored on secure servers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot completely guarantee the security or confidentiality of any communication or material transmitted to/from Breakthrough Biotech Law via this Site or any other electronic means, including email. Accordingly, Breakthrough Biotech Law is not responsible for the security of information transmitted via the Internet. 

Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorized access. We also keep your Personal Information confidential. 

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties. This includes any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

RIGHT TO OPT OUT/UNSUBSCRIBE

Where required under applicable data privacy laws, Breakthrough Biotech Law will not send any promotional materials to you unless you have opted into receiving these communications. Additionally, at any time, you may opt out of having your Personal Information used by us to send promotional correspondence to you by contacting us via telephone, email, or mail. You may also “unsubscribe” from our email list at any time by clicking the “unsubscribe” button in any communication from Breakthrough Biotech Law.

We will try to comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages from which you cannot opt out.

RETENTION OF YOUR INFORMATION

Breakthrough Biotech Law will only retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected by us, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your Personal Information, we consider the amount, nature, and sensitivity of your 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, including the statute of limitations periods.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

CROSS-BORDER TRANSFER

Due to the global nature of the internet infrastructure, the information you provide may be transferred in transit to countries outside of the jurisdiction in which you reside that may not have similar protections in place regarding your Personal Information and its use as set out in this Privacy Policy.  By submitting your Personal Information, you acknowledge that your Personal Information may be transferred outside of your jurisdiction. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.  

CONTACTING US

Breakthrough Biotech Law has a business address of 1049 El Monte Ave, Ste C882, Mountain View, CA, 94040, United States, and is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.  If you have any questions about this Privacy Policy, please contact us at info@btbtlaw.com.

ADDITIONAL INFORMATION REGARDING THE EEA AND THE UK

You may lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. A list of EEA data protection authorities is available at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Information regarding the UK data protection authority is available at: https://ico.org.uk/.

ADDITIONAL INFORMATION REGARDING CALIFORNIA

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about  California residents that we collect, use, and disclose about California residents and households.

Sources of Personal Information

As described above, we collect your Personal Information from you, our affiliates, partner organizations, publicly available databases, social media platforms, and joint marketing partners and event sponsors. 

Use of Personal Information

Also as described above, we may use your Personal Information to operate, manage, and maintain our business, to provide our services, for vendor and employment management, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: provide Services; personalize, advertise, and market our services and provide you with content and events of interest; conduct research, analytics, and data analysis; host conferences and events; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; facilitate corporate transactions; and exercise and defend legal claims. 

Under the CCPA, if a business sells Personal Information, it must allow California residents to opt out of the sale of their Personal Information. However, we do not “sell” and have not “sold” Personal Information in the preceding 12 months for purposes of the CCPA. For example, and without limiting the foregoing, we do not "sell" the Personal Information of minors under 16 years of age.

Individual Rights and Requests

If you are a California resident, you may request that we:

Disclose to you the following information covering the 12 months preceding your request:

The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information; the specific pieces of Personal Information we collected about you; the business or commercial purpose for collecting Personal Information about you; and the categories of Personal Information about you that we shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information. To make a request for the disclosures or deletion described above, please use our online form which you can find here, or email us at info@btbtlaw.com.  

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. For your protection, we may need to request additional information from you (such as your name, email address, mailing address, and relationship with us) in order to verify your identity and protect against fraudulent requests. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Authorized Agents

If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include proof of your registration with the California Secretary of State to conduct business in California; and/or a power of attorney from the California resident pursuant to Probate Code sections 4121-4130.

If you are making a request on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to verify the resident’s own identity directly with us; or directly confirm with us that the resident provided you permission to submit the request.

California “Shine the Light” Disclosures

Breakthrough Biotech Law may disclose Personal Information to affiliates to use this information for all purposes outlined in this Privacy Policy. Because separate legal entities are considered “third parties” for purposes of California Civil Code Section 1798.83, certain communications from our affiliates might be viewed as promoting their legal services. If you would like to learn more about this or to make a request to discontinue this type of sharing, please email us at info@btbtlaw.com.   

The following chart details which categories of Personal Information about California residents Breakthrough Biotech Law may collect, as well as which categories of Personal Information that may be disclosed.

Category of Information	To Whom Information May Be Disclosed
Identifiers such as name, postal address, online/device identifier, IP address, email address and social media account.	Affiliates, service providers, and other vendors
Personal information as defined in the California customer records law, such as name, signature, contact information, and social media account handle and other information you may share or make public on social networks.	Affiliates, service providers, and other vendors
Characteristics of protected classifications under California or federal law, which we may collect in order to provide you with our Client Services, such as age.	Affiliates, service providers, and other vendors
Commercial information, such as Client Services transaction history, financial details and payment information.	Affiliates, service providers, and other vendors
Biometric information, such as fingerprints and voiceprints.	Not collected
Internet or other electronic network activity information, such as browsing history and interactions with our Websites, applications, systems, and emails.	Affiliates, service providers, and other vendors
Geolocation data, such as device location and IP location.	Affiliates, service providers, and other vendors
Audio, electronic, visual and similar information, such as call recordings and CCTV footage created for safety and security purposes, and audio and video recordings of events, conferences and meetings.	Affiliates, service providers, and other vendors
Professional or employment-related information, such as employer name and role/title.	Affiliates, service providers, and other vendors
Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.	Affiliates, service providers, and other vendors
Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.	Not collected