PRIVACY POLICY
Last updated March 27, 2023
This privacy notice for CarboGrove ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our
services ("Services"), such as when you:
• Visit our website at carbogrove.org, or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events
1. DATA USE AND STORAGE
Data submitted to the MotifFinder web tool is uploaded to a webserver securely hosted by Amazon
Web Services for processing and analysis. The data is stored on the webserver for 3 days following
completion of the analysis. After the analysis has been completed for 3 days both the submitted
data and all results are permanently deleted from the webserver.
While data is stored on the carbogrove webserver, it can only be accessed by those who maintain
the server. Results can be accessed by those who maintain the server and the user through the link
provided. We advise users to bookmark or otherwise store the “waiting” page presented after data
submission as that page will redirect the user to the results when they are available.
While data and results are accessible by those who maintain the server, they will not view the data
or results barring expressed permission at the request of the user who submitted the data. Users
will be asked to provide the unique job identifier generated for their submitted data. Note that this
job identifier can be used to view the results and should only be shared with those who you are
comfortable sharing the data and results with.
For users concerned with the stated data use and storage protocol we advise them to download the
standalone MotifFinder application to run analyses locally and securely.
2. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in
activities on the Services, or otherwise when you contact us.
Sensitive Information. We do not process sensitive information.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but
may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country,
location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services,
and for our internal analytics and reporting purposes.
The information we collect includes:
• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services
and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information
about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features
you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this
device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service
provider and/or mobile carrier, operating system, and system configuration information.
However, if you choose to opt out, you may not be able to use certain aspects of the Services.
3. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
4. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or I-JK, this section applies to you.
The General Data Protection Regulation (GDPR) and I-JK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on
the following legal bases to process your personal information:
• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at
any time. Learn more about withdrawing your consent.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh
your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
• Analyze how our Services are used so we can improve them to engage and retain users
• Diagnose problems and/or prevent fraudulent activities
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving
potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your
permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related
to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a
portion of our business to another company.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless othetwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such
as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is
possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the
Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such
a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the
account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact
us at Zachary.Klamer@vai.org.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (I-JK), and Canada, you have rights that allow you greater access to and control over your personal
information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, I-JK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your
personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you
may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection
authority or I-JK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing_your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you
have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information
conducted in reliance on lawful processing grounds other than consent.
If you have questions or comments about your privacy rights, you may email us at Zachary.Klamer@vai.org.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As
such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is
adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we
shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us
using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the
Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that
you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all
our systems (e.g., backups, etc.).
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at Zachary.Klamer@vai.org, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on
your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that
processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to
be "selling" of your personal information.
CarboGrove has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.
CarboGrove will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to
certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal
obligation, or any processing that may be required to protect against illegal activities.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible.
If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to
review this privacy notice frequently to be informed of how we are protecting your information.
