Privacy Policy

PENDULUM THERAPEUTICS PRIVACY POLICY

Pendulum Therapeutics Inc. (“Pendulum Therapeutics”, “we” or “us”) is committed to maintaining the privacy of your personal information collected through the website(s) managed and operated by Pendulum Therapeutics, including: www.pendulum.co and www.betabiome.com, any of their subdomains, or any related sites, applications, widgets or online services offered by Pendulum Therapeutics (individually or collectively referred to as the “Site”).  This Privacy Policy discloses Pendulum Therapeutics’ information collection and dissemination practices in connection with the Site and applies solely to the information that we collect through the Site.  Pendulum Therapeutics is acting as the controller of the Site as well as any data or information you submit via this Site, unless expressly indicated otherwise when you submit such data or information.  This Privacy Policy does not address personal information that you provide to us in other contexts (e.g., through a third party controlled site, or through a business or investment relationship not handled through the Site).

ACCEPTANCE OF PRIVACY POLICY

By using the Site, you signify your acceptance of this Privacy Policy.    Your continued use of the Site following the posting of changes to these terms will mean that you accept those changes. If you do not agree to the terms of this Privacy Policy, do not use the Site.

WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy covers how Pendulum Therapeutics treats personal information (“PI”) that we collect and receive through the Site.  PI is information that may or may not be information about you that is personally identifiable, and is not otherwise publicly available. PI that we may collect, use, store and transfer may include different kinds of personal data about you, which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this site.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences and any feedback or surveyed responses. This category may also include employment and education history in the event that this personal data is provided to us in the case of career submissions.
  • Usage Data includes information about how you use our site, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

How Personal Information Provided By You May Be COLLECTED AND Used

We use the information that we collect from you to provide you with products and services (collectively “Services”), support and enhance your use and access of the Services, to monitor which features of the Services are of most interest and to allow us to determine which features we need to focus on improving. If you choose to provide us with PI, you consent to the transfer and storage of that information on our servers located in the United States, and to the use of that PI in accordance with the terms of this Privacy Policy.

Except as described in this Privacy Policy, Pendulum Therapeutics only collects your PI through this Site when you choose to provide such information, such as when you enter your e-mail address to use the “Contact Us” feature, when you submit answers to questions or surveys posed through the Site or when you request or purchase Services through the Site.

Pendulum Therapeutics will only use your PI in compliance with current laws.  In some cases, Pendulum Therapeutics may use PI submitted by you, such as your answers to questions or surveys about our products or services, your demographic or geographic information, to demonstrate the value of our products and/or services in marketing and/or advertising materials or media.  In such cases, Pendulum Therapeutics shall not identify you as the source of such information without your express consent, and absent such consent, shall ensure that any such presented information is anonymized so that the information will not be attributable to you when and as presented.

Pendulum Therapeutics will not sell, rent, license, or trade your PI with third parties for their own direct marketing use unless we receive your express consent to do so.  Unless you give us permission to do so, Pendulum Therapeutics will not share your PI other than as specified in this Privacy Policy.

Disclosures to Third Parties Assisting In Our Operations  

Pendulum Therapeutics may share your PI under confidentiality agreements with other companies that work with, or on behalf of, Pendulum Therapeutics, to provide products and services.  These companies may use your PI to assist Pendulum Therapeutics in its operations.  These companies do not, however, have any independent right to share this information.

Disclosures Under Special Circumstances. We may disclose your PI to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims.  We may also disclose your PI if we believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

Business Transfers.  We may share your PI with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of Pendulum Therapeutics' business to such business entity.  We will require any such successor business entity to honor the terms of this Privacy Policy.

AUTOMATICALLY COLLECTED INFORMATION AND ANONYMOUS INFORMATION

Each time a visitor comes to the Site, Pendulum Therapeutics collects some information to improve the overall quality of the visitor’s online experience.

Aggregated Data. Pendulum Therapeutics collects aggregate queries for internal reporting and also counts, tracks, and aggregates the visitor’s activity into Pendulum Therapeutics' analysis of general traffic-flow at the Site.  Pendulum Therapeutics may also remove personal identifiers from PI and maintain it in aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information.  Pendulum Therapeutics may share, publicly or privately, anonymized or aggregated information from the Site.  If Pendulum Therapeutics shares aggregate information, it will do so in a manner that no individual can be identified.

Web Server Logs and IP Addresses.  An Internet Protocol (“IP”) address is a number that automatically identifies the computer/device you have used to access the Internet.  The IP address enables our server to send you the web pages that you want to visit, and it may disclose the server owned by your Internet Service Provider.  Pendulum Therapeutics may use IP addresses to conduct website analyses and performance reviews and to administer the Site.

Cookies and Web Beacons.  We use cookies on our Site.  Cookies are pieces of information that a website transfers to a user’s computer for purposes of storing information about a user’s preferences.  Cookies in and of themselves do not personally identify users, although they do identify a user’s computer.  Many websites use cookies as a standard practice to provide useful features when a user visits the website and most web browsers are set up to accept cookies. Pendulum Therapeutics uses cookies to improve your online experience when visiting the Site.  We will ask you to consent to our use of cookies when you first visit our Site, and you can set your browser to refuse cookies, but some portions of the Site may not work properly if you refuse cookies.  Some of the Site’s web pages may use web beacons in conjunction with cookies to compile aggregate statistics about website usage.  A web beacon is an electronic image (also referred to as an “action tag,” “single-pixel,” or “clear GIF”) that is commonly used to track the traffic patterns of users from one web page to another in order to maximize web traffic flow and to otherwise analyze the effectiveness of websites.  Some web beacons may be unusable if you elect to reject their associated cookies.

Pendulum Therapeutics may participate in behavioral-based advertising. This means that a third party may place a cookie on your browser, or use a web beacon, to collect information about your use of our Site so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on our Site or on other websites. If you would like to opt-out from having the behavioral-based advertising companies with whom we have a relationship use your information for advertising purposes you can do so by visiting the Network Advertising Initiative or Digital Advertising Alliance.

Pendulum Therapeutics may also use services hosted by third parties, such as Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to assist in providing the Services.  Google Analytics uses cookies to help us analyze how users use the Services. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to, and stored by, Google on their servers. Google will use this information for the purpose of evaluating your use of the Services, compiling reports on website activity for us and providing other services relating to website activity and Internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.  You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Services.  By using this Services, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

REFERRALS/LINKS

The Site may contain links to third-party websites that may offer information of interest.  This Privacy Policy does not apply to those websites, and Pendulum Therapeutics recommends reviewing those websites’ privacy policies individually.  Pendulum Therapeutics assumes no responsibility for any material outside of the Site, including any website that may be accessed through a link from the Site.

SECURITY

Pendulum Therapeutics takes measures it believes are reasonably designed to protect the PI that it receives from you from unauthorized access, use and alteration.  We believe, however, that a persistent attacker with sufficient resources would be able to defeat our security measures.  Therefore, we provide no guarantee that your PI will remain secure.

RESPONSE TO “DO NOT TRACK” SIGNALS

Some Internet browsers include the ability to transmit “Do Not Track” signals.  Since uniform standards for “Do Not Track” signals have not yet been adopted, Pendulum Therapeutics does not process or respond to “Do Not Track” signals.

CHILDREN’S PRIVACY PROTECTION

The Site is not intended for use by persons under 18 years old.

CALIFORNIA

California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of PI to third parties for their direct marketing purposes.  To make such a request, you may contact us by e-mail at hello@pendulum.co.

CHANGES

You may review and request changes to your PI that Pendulum Therapeutics has collected, including the removal of your PI from Pendulum Therapeutics' databases in order to prevent receipt of future communications, using any of the following options:

You can send your request via e-mail to: contact@pendulum.co