Privacy

Privacy Policy Notice

Effective Date: May 28, 2020

This Privacy Policy Notice (“Notice”) describes how Elevation Oncology, Inc. (“Elevation Oncology,”, “we”, “our” or “us”) collects and processes personal information online through legal@elevationoncology.com and all other Elevation Oncology, websites and applications (the “Services”) that link to this Notice.  

We will review and update this Notice periodically in response to changing legal, technical, market, and business developments.  When we update this Notice, we will note the date of its most recent revision above.  We will take commercially reasonable measures to inform all users in a manner that is consistent with the significance of the changes we make and in accordance with applicable law.  Your continued access to or use of the Services after we have posted changes to this Notice on this page as set forth above, and have otherwise complied with the applicable laws regarding changes in the notice, will indicate that you agree to be bound by such changes. 

1. PERSONAL INFORMATION THAT WE COLLECT

Personal information is information, or a combination of pieces of information, that could reasonably allow you to be identified. We collect personal information from a variety of sources, including from you directly (e.g., when you contact us via our website or sign up for our newsletters), information we generate about you in the course of our relationship with you (e.g., data collected from cookies and similar technologies as described in our Cookies Policy below), and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law). We may also collect certain personal information about you as required by law, or as a consequence of our contractual relationship. Failure to provide this information may prevent or delay the fulfillment of these obligations. Note that we and our service providers may automatically collect certain technical information from your computer or mobile device over time and across different websites when you use the Services. 

We may collect the following categories of personal information from and about you:

• Identifiers such as a name, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers;
• Demographic information, including characteristics that may be protected by law such as gender or age; 
• Internet or other electronic network activity information, such as the data we receive when you interact with our website;
• Audio, electronic, visual, thermal, olfactory, or similar information, such as photographs or voice recordings;
• Professional or employment-related information, such as your employer or title; and
• Education information, such as the university you attended and degree.
• Geolocation data, such as information we receive about your device location (e.g., based on your IP address);

2. HOW WE USE YOUR PERSONAL INFORMATION 

We may use your personal information for the legitimate interest of our business as follows:

• Identification and authentication: We use your identification information to verify your identity when you access and use our Services, or otherwise engage with us, and to ensure the security of your personal information. This is necessary to provide the requested service.
• Service operations: We process your personal information to provide the Services that you request. 
• Service improvements: We analyze usage information, including site analytics, to continually improve the user experience. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand issues and make necessary improvements. 
• Communications: Communications may include providing information about changes to the terms and conditions, updates regarding our services, employment-related information, or responses to questions you pose. 
• Marketing: We may use your personal information to build a profile about you, to understand your preferences, and to help determine which marketing materials (for example, region- or sector-focused) would be of interest to you. Where necessary, we will obtain your consent before sending such marketing materials. 
• Exercising our rights: We may use your personal information to exercise our legal rights where it is necessary to do so, for example to detect, prevent, and respond to intellectual property infringement claims or violations of law.
• Complying with our obligations: We may process your personal information to carry out fraud prevention checks or comply with other legal or regulatory requirements, when required by law.
• Customizing your experience: We may use your personal information to improve your experience of the Services, such as by providing interactive or personalized elements on the Services and providing you with content based on your interests.

• Identification and authentication: We use your identification information to verify your identity when you access and use our Services, or otherwise engage with us, and to ensure the security of your personal information. This is necessary to provide the requested service.
• Service operations: We process your personal information to provide the Services that you request. 
• Service improvements: We analyze usage information, including site analytics, to continually improve the user experience. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand issues and make necessary improvements. 
• Communications: Communications may include providing information about changes to the terms and conditions, updates regarding our services, employment-related information, or responses to questions you pose. 
• Marketing: We may use your personal information to build a profile about you, to understand your preferences, and to help determine which marketing materials (for example, region- or sector-focused) would be of interest to you. Where necessary, we will obtain your consent before sending such marketing materials. 
• Exercising our rights: We may use your personal information to exercise our legal rights where it is necessary to do so, for example to detect, prevent, and respond to intellectual property infringement claims or violations of law.
• Complying with our obligations: We may process your personal information to carry out fraud prevention checks or comply with other legal or regulatory requirements, when required by law.
• Customizing your experience: We may use your personal information to improve your experience of the Services, such as by providing interactive or personalized elements on the Services and providing you with content based on your interests.

We may also anonymize your personal information in such a way that you may not reasonably be re-identified by us or any other company, and may use this anonymized information for any other purpose. 

3. HOW AND WHEN WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information as follows:

• To inform third-party entities that provide services to us: We may share your personal information with suppliers, subcontractors and other third parties who support our business operations. For example, we may partner with companies to process secure payments, fulfill orders, optimize services, support email and messaging services, and analyze information. These service providers may include advertising agencies and fraud prevention agencies which will use your personal information only in the ways described in this notice.  
• When general laws allow us to do so, we may share your personal information with third parties that provide marketing services such as sending newsletters and other marketing messages.  In jurisdictions where such activities are not permitted without the prior explicit consent of the individuals, we refrain from conducting these activities. 
• Where required by law: We may share your personal information with law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
• In the context of a transaction: We may share your personal information with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer your personal information to use it in a manner consistent with this Privacy Notice. 

4. CHILDREN’S PRIVACY PROTECTION

We have not targeted children that are under 13 years of age in designing the Website.  If you are under the age of 13, you should not use, or submit any Personal Information to, this Website; if you would like to access our Website and the information and services we provide, consult your parent or guardian and ask him or her to access our Website on your behalf.  Please contact us if you believe any Personal Information about a child under the age of 13 has been submitted to us without parental or guardian consent.  If we obtain actual knowledge that we have collected personal information from a child under the age 13, we will take steps to delete such information from our database. 

If you are a California resident under the age of 16, do not share any personal information without parental consent.  

5. YOUR RIGHTS OVER YOUR PERSONAL INFORMATION 

You have certain rights regarding the personal information we hold about you, subject to local law. These may include the right to access, correct, delete, restrict or object to our use of, or receive a portable copy in a usable electronic format of your personal information. You also may have a right to lodge a complaint with your local data protection or privacy regulator.

We also encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. Where you have provided your consent to any use of your personal information, you can withdraw this consent at any time. Please note that we may require additional information from you in order to honor your requests. 

If you would like to discuss or exercise any rights you may have under law, please contact us at legal@elevationoncology.com.

For additional information regarding your rights related to our use of cookies, please see our Cookies Policy below. 

6. DATA RETENTION 

We retain your personal information for as long as we have a relationship with you. After our relationship has ended, we retain your information as long as required by law. We may also retain records to investigate or defend against potential legal claims.

7. COOKIES POLICY

Cookies

A cookie is a small text file that can be placed on your computer’s hard drive with your permission. The cookie helps analyze web traffic and lets you know when you visit a particular site. Cookies allow web applications to respond to your individual preferences when online and tailor operations by gathering and remembering information about your preferences.

When you visit the Services, we may use cookies.  In some countries, we are not permitted to send cookies to the browser of a user without the prior consent of the affected user.  In this case, we will seek such consent.  The remainder of this section assumes that either the use of cookies is not restricted by applicable law, or if it is restricted that the individual has explicitly consented to the use of the cookies.

Cookies help Elevation Oncology, provide a better user experience on our website by monitoring which pages are most frequently visited. A cookie does not give Elevation Oncology, access to your computer or provide any information other than the data you choose to share. 

If you do not want the Services to collect information through the use of cookies, you can set your web browser to reject cookies from the Services. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. If you reject or block cookies from the Services, however, the Services may not function as intended.

You may also visit https://optout.aboutads.info/ or https://www.networkadvertising.org/ to exercise your cookie preferences. 

Analytics

The Elevation Oncology, website uses analytics to help improve both the user experience and functionality. Elevation Oncology, uses external services, including Google Analytics, to attain real-time statistics on use and navigation of the website, including page views, traffic patterns, visit counts, and visit statistics. These services are not used to gather, request, record, require, collect, or track personally identifiable information.

Third-Party Cookies

Our website also uses additional external services. These external services may employ the use of cookies. More information on these external services and their data/privacy policies can be found by following the link(s) below:

• DoubleClick privacy policy: https://policies.google.com/privacy?hl=en

Elevation Oncology does not control any third party’s use of cookies or their privacy notice compliance. Users should use caution when accessing these external services.

You may reject the use of some or all of the cookies used on the Elevation Oncology, website. Please refer to your browser’s help file for the steps required. Please note that modifying browser settings to reject some or all cookies may impact user experience on the Elevation Oncology, website. Modification may also impact the delivery of personalized content. 

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. For more information, visit www.allaboutdnt.org.

8. INTERNATIONAL DATA PROCESSING & TRANSFER

Information collected through the Services will be processed in and subject to the laws of the United States, which, if you are not located in the United States, may not provide the same level of protection for your personal information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries. By accessing the Services, you grant us expressed consent to transfer your personal information to US servers. 

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information. For more information on the appropriate safeguards in place, and to obtain a copy of such safeguards, please contact us at the contact information set forth below. 

9. FOR CALIFORNIA RESIDENTS

California law requires that a business provide in its privacy notice a list of the categories of personal information it has in the preceding 12 months (1) disclosed for a business purpose, and (2) disclosed in exchange for valuable consideration (considered a “sale” under California law, even if no money is exchanged), as well as the categories of third parties to whom each category of personal information was disclosed or sold. In accordance with California law: 

Categories of personal information disclosed for our business purposes	Categories of third parties to whom this information was disclosed
Identifiers	Elevation Oncology, affiliates and vendors and service providers who help us provide services
Demographic information	Elevation Oncology, affiliates and vendors and service providers who help us provide services
Internet or other electronic network activity information	Elevation Oncology, affiliates and vendors and service providers who help us provide services
Audio, electronic, visual, thermal, olfactory, or similar information	Elevation Oncology, affiliates and vendors and service providers who help us provide services
Professional or employment-related information	Elevation Oncology, affiliates and vendors and service providers who help us provide services
Education information	Elevation Oncology, affiliates and vendors and service providers who help us provide services

California law also grants its residents certain rights regarding the collection and use of their personal information. Subject to certain limitations, California residents have the following rights:

• Right to know. You have the right to know and request information about the categories and specific pieces of personal information we have collected about you within the last 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information. 
• Right to delete. You have the right to request the deletion of your personal information, subject to certain exceptions. 
• Right to non-discrimination. You have the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information. 

If you are a California resident and would like to exercise any of the above rights, please submit your request Elevation Oncology, Inc. 888 7th Ave, 12th Floor, New York, NY 10106 or legal@elevationoncology.com. Please note that we may require additional information from you in order to honor your request, and there may be circumstances where we will not be able to honor your request. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations or other permitted purposes. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request. If you are submitting a request through an authorized agent, the authorized agent must provide us with your signed written permission stating that the agent is authorized to make the request on your behalf. We may also request that any authorized agents verify their identity and may reach out to you directly to confirm that you have provided the agent with your permission to submit the request on your behalf. 

Finally, if you reside in California and have provided your personal information to us, you may request information once per calendar year about our disclosures of certain categories of your personal information to third parties for their direct marketing purposes. Such requests must be submitted to us in writing at the following email address legal@elevationoncology.com.

10. CONTACT US

If you have questions or concerns regarding the way in which your personal information has been used, please contact us at legal@elevationoncology.com.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country of residence.