Orlucent, Inc. Privacy Policy

 

Last Updated: April 19, 2018

 

This Privacy Policy (“Policy”) describes the manner in which Orlucent, Inc. (“Orlucent,” “we,” or “us”) collects, uses, and discloses Personal Information about you in the context of our website www.orlucent.com and any localized versions thereof (the “Website”) or in relation to our communications with you. This Policy is incorporated into and is subject to the Orlucent Terms of Use. By using the Website, you consent to the processing of your information as set forth in this Privacy Policy.

 

Personal Information We Collect:

 

• User-provided Information. You may provide and we may collect and store various types of information, including information that relates to an identified or identifiable individual (“Personal Information”). Examples of Personal Information include name, email address, postal address, and phone number. Personal Information also includes other information, such as geographic area, and preferences, when that information can be linked to an identified or identifiable individual. You may provide us with Personal Information in various ways, including by indicating your location on the landing page of the Website, communicating with our team, or sending us other communications.

 

• Cookies and Automatically Collected Information. When you use the Website, we may, now or in the future, send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Website. Please review your web browser “Help" file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from the Website, you may not be able to utilize the features of the Website to their fullest potential. We may, now or in the future, use third party cookies on our Website as well. For instance, we may use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at www.google.com/policies/privacy/partners/ regarding Google Analytics cookies. Orlucent does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who visit our Website.

 

We may also automatically record certain information from your device by using various types of technology, including “clear gifs" or “web beacons.” This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Website, the pages or other content you view or otherwise interact with on the Website, and the dates and times that you visit, access, or use the Website. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users, and may be connected with other information about you.

 

• Location Information.  We may obtain information about your physical location when you indicate your location on the landing page of the Website or by inference from other information we collect (for example, your IP address indicates the general geographic region from which you are connecting to the Internet).

 

• Third Party Web Beacons and Third Party Buttons. We may display third-party content on the Website. Third-party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with your viewing of the third-party content on the Website. Additionally, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by Orlucent. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.

 

• Information from Other Sources. We may obtain your name and email address from third parties, such as our partners.

 

When We Collect Personal Information

We may collect and use your Personal Information when:

• You have consented to the use of your Personal Information. For example, we may seek to obtain your consent for our uses of cookies or similar technologies or to send you marketing communications.

 

• We need your Personal Information to provide you with products and services, or to respond to your inquiries.

 

• We have a legal obligation to use your Personal Information.

 

• We, or a third party, have a legitimate interest in using your Personal Information, such as to ensure and improve the safety, security, and performance of our products and services, to provide you with the correct version of our Website or carry out data analyses.

 

We indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so, at the time of the collection of your Personal Information. If you do not provide the Personal Information necessary to provide you with our products and services, you will not be able to benefit from them.

 

How We Use the Personal Information We Collect. We use Personal Information we collect in a variety of ways in providing the Website and operating our business, including the following:

 

• We use the Personal Information that we collect to operate, maintain, enhance and provide all features of the Website and our business, to provide our products and services and information that you request, to ensure that you are visiting the correct location-based landing page, to respond to comments and questions and otherwise to provide support and communicate with users.

 

• We use the Personal Information that we collect to understand and analyze the usage trends and preferences of our users, to improve the Website, and to develop new products, services, features, and functionality.

 

• We may use cookies and automatically collected information to: (i) personalize our Website, such as remembering information about you so that you will not have to re-enter it during your visit or the next time you visit the Website; (ii) monitor and analyze the effectiveness of the Website; and (iii) monitor aggregate site usage metrics such as total number of visitors and pages viewed.

 

• We may use Personal Information to contact you for administrative purposes such as customer service or to send tailored marketing communications, including updates on promotions and events, relating to products and services offered by us and by third parties.

 

When We Disclose Personal Information. Except as described in this Policy, we will not disclose Personal Information about you that we collect on the Website to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

 

• We work with third party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process information about you as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.

 

• We use third party analytics partners to evaluate and provide us with information about your use of the Website. These analytics service providers may set and access their own cookies, pixel tags and similar technologies on the Website and they may otherwise collect or have access to Personal Information which they may collect over time and across different websites.

 

• We may disclose information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable legal requirements, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

 

• We also reserve the right to disclose information about you to third parties where we believe, in good faith, that such disclosure is appropriate or necessary to: (i) take precautions against liability; (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity; (iii) investigate and defend ourselves against any third-party claims or allegations; (iv) protect the security or integrity of the Website and any facilities or equipment used to make the Website available; or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

 

• Information about our users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

 

• We may make certain aggregated, automatically-collected, or otherwise non-Personal Information available to third parties for various purposes, including compliance with various reporting obligations or other business purposes.

 

Your Choices

 

You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Website. If you wish to access or amend any other Personal Information we hold about you, you may contact us at [email protected]. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so to the extent permitted under applicable law.

 

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial email from us by sending your request to us by email at [email protected] or by writing to us at the address given at the end of this policy. Please be aware that even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Website.

 

If you are located in the European Economic Area (“EEA”), you also have the right to:

 

• Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

 

• Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

 

You may exercise the rights listed above by contacting us as described in the “How to contact us” section below.

 

Third-Party Services

 

The Website may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Website. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Website. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

 

Children’s Privacy

 

Protecting the privacy of children is especially important. Our Website is a general audience site not directed to children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16without obtaining parental consent.

 

Data Security

 

We use appropriate physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

 

Data Retention

 

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process that information or when you request their deletion unless we are required by law to keep the information for a longer period. We have established specific time limits for data deletion in our data retention policies and complete periodic review of our databases, taking into account the type of services provided in the context of the Website, the length of the relationship, mandatory retention periods and the statute of limitations.

 

International Visitors

 

We may transfer your Personal Information to recipients in countries other than your country, including without limitation to the United States. These countries may not have the same data protection laws as the country in which you initially provided the information.

 

When we transfer Personal Information outside of the European Economic Area, we will comply with applicable EU data protection laws. We may transfer your Personal Information to countries which provide an adequate level of protection under EU law. By accessing this Website, you agree to the transfer of your Personal Information to countries other than your country.

 

Changes and Updates to this Policy

 

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Website, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send generate a pop-up or similar notification when you access the Website for the first time after such material changes are made. Your continued use of the Website after the notification of the changes to this Privacy Policy indicates that you have read, understood and agreed to the current version of this Policy.

 

Your California Privacy Rights

 

Residents of California have the right to request a disclosure describing what types of Personal Information we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year. You may request a copy of that disclosure by contacting us at [email protected].

 

How to Contact Us

 

Orlucent Inc. is the entity responsible for the processing of your Personal Information. Please contact us with any questions or comments about this Policy, information we have collected or otherwise obtained about you, our use and disclosure practices, or your consent choices by email at [email protected].

 

Orlucent, Inc.

61 E. Main Street, Suite B

Los Gatos, CA 95030