Caribou Biosciences, Inc.
Privacy Policy

Table of Contents

Overview
1.    Collection of Information
2.    Use of Information
3.    Sharing of Information
4.    Analytics Services Provided by Others
5.    Linked Websites
6.    User-Provided Content
7.    Children
8.    Security
9.    Transfer of Information to the U.S. and Other Countries
10.   Your Choices
11.   Your Privacy Rights
12.   Contact Us

Overview

This Privacy Policy (this “Privacy Policy”) explains how information about you is collected, used, and disclosed by Caribou Biosciences, Inc. ("Caribou,” “we,” “us,” or “our”). This Privacy Policy applies to information collected on our website located at https://www.cariboubio.com (the “Website”). This Privacy Policy does not apply to (1) websites, partner sites, software applications, and other online properties and services that do not link directly to this Privacy Policy; and (2) any other collection, use, or disclosure of data other than via the Website. This Privacy Policy is not intended to and does not create any contractual right on behalf of any party. Where required under applicable law, we will separately seek appropriate consent to the collection, use, and disclosure of Personal Information, as defined below.

Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household. We do not consider Personal Information to include information that has been aggregated or de-identified so that it does not allow a third party to easily identify a specific individual.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). Your continued access to or use of the Website after any such modifications constitutes your acceptance of the Privacy Policy as modified. As a result, we encourage you to review the Privacy Policy whenever you access the Website or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy. If you do not agree to any amended terms, you must stop using the Website. If any modification to this Privacy Policy is held to be invalid, void, or unenforceable for any reason, such modification shall be deemed severable and shall not affect the validity and enforceability of this Privacy Policy.

1.     Collection of Information

Information You Provide to Us

If you signed-up for a customer account, inquired about a license to intellectual property, applied for a job, or contacted us through the Website in the past twelve (12) months, we or our service providers may have collected Personal Information that you provided including the following:

  • Personal Identifiers: including your name, company information, position, email address, postal address, phone number;
  • Professional or employment-related information: including your current or past job history, education, personal references, and other information used for monitoring and background checks to comply with laws and regulations;
  • Website or Social Media Information: including information you share in communications to us, and content you share in reviews, comments, or questions posted on the Website, social media pages, etc.
  • General Business Information: including payment and invoice data used to calculate accounts receivable and accounts payable; and
  • Clinical Trial Information: including information, content, and questions you communicate to us regarding our clinical trials.

This information may be supplied by you in response to specific questions, when you sign up for or request communications from us, or communicate with us in person or by email. You can always refuse to supply Personal Information in response to requests, except that it may prevent us from completing your request or concluding your interaction.

We ask that you not send us any sensitive Personal Information about yourself or others (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, sex life or sexual orientation, criminal background, trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the Website.

Information Received From Third Parties

We may combine Personal Information that you provide to us with Personal Information that we collect from, or about, you from other sources in some circumstances. In the past twelve (12) months, this Personal Information may have included the following:

  • Background Check Information: Reference information or information received from background checks (where applicable).

Information We Collect Automatically When You Use the Services

When you access or use our Website, we automatically collect information about you. In the past twelve (12) months, such information may have included the following:

  • Log Information: We collect log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
  • Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see the "Your Choices" Section below.
  • Transaction Information: We collect transaction details related to your purchases through the Website.

2.     Use of Information

We may use information about you for various purposes, including to:

  • Provide, maintain, and improve our Website;
  • Respond to your comments, questions, and requests;
  • For our job candidate recruitment, when you apply for a position with us;
  • Communicate with you about news and events  relating to Caribou and others that we think will be of interest to you;
  • Monitor and analyze trends, usage, and activities in connection with our Website; and
  • Carry out any other purpose described to you at the time the information was collected.

3.     Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

  • With vendors, consultants, and other service providers who need access to such information to carry out work on our behalf, with your consent where required;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, or legal process;
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of Caribou or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
  • Between and among Caribou and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
  • With your consent or at your direction.

Where we share your information with vendors, consultants, and other service providers, such service providers will only have access to the information needed to perform work on our behalf and are prohibited from using the information for other purposes except as permitted by law, such as for fraud detection and maintaining their services, or upon your consent. In the past twelve (12) months, such service providers included the following:

  • Customer Experience Partners: We may provide your Personal Information, including Site and Social Media information, in order to help us improve the Website and our products.
  • IT Service Providers: Such service providers perform functions such as data hosing, operating, and supporting the Website, and analyzing data. IT Service Providers may have access to Personal Information such as personal identifiers, account credentials, usage information, device information, cookie information, and transaction information.
  • Human Resources Services and Background Check Providers: In order to consider your application for employment, validate your information, and carrying out reference checks and/or conducting background checks (where applicable).
  • Other Service Providers: We may engage to provide services to us or on our behalf, with your consent or direction, or as otherwise permitted or required by law.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you; however, we do not sell, rent, or lease our user lists or the identity of individual users to third parties. We may also disclose Personal Information if we become subject to a subpoena or court order, or if we are otherwise legally required to disclose information. We may also use and disclose Personal Information to establish or exercise our legal rights, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the well-being of any person.

4.     Analytics Services Provided by Others

We partner with third-party analytics providers to better understand your use of our Website. We use analytics partners (such as Google Analytics) to help analyze usage and traffic for our Website. As an example, we may use analytics partners to analyze and measure, in the aggregate, the number of unique visitors to our Website. These third parties may collect information sent by your computer, browser, or mobile device in response to a request for content, such as unique identifiers, your IP address, or other information about your computer or device. Some of the areas of the Website may also contain electronic images known as web beacons (sometimes known as clear gifs) that allow us, and our third-party providers or affiliates, to count and track users who have visited certain portions of the Website.

5.     Linked Websites

For your convenience, some hyperlinks may be posted on the Website that link to other websites not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that we do not own or control. We cannot be responsible for the privacy practices of any such websites or pages not under our control and we do not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. We encourage you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a website that our Website links to, even if you reached that site through the System, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website’s privacy policies to understand how Personal Information that is collected about you is used and protected.

6.     User-Provided Content

Any information, communications, or material of any type or nature that you submit to the Website or any mobile application by e-mail, posting reviews, messaging, or otherwise (collectively, a “Submission”) is done at your own risk. We cannot control the actions of other users of the Website and we are therefore not responsible for any Submissions contained on the Website.

Additionally, in the event that we offer a message board or any other interactive or social-type feature on the Website, please be aware that these areas may allow you to post, and share with other users, certain messages, content, or other information. We encourage you to be wary of giving out any Personal Information, or any Personal Information of others to which you may have access, in such forums. The information you post can be collected and used by other people.

7.     Children

The Website is intended for a general audience and is not intended for use by children under 13 years of age. Consistent with the Children’s Online Privacy Protection Act, we do not and will not knowingly collect information about children on children under the age of 13.

8.     Security

Caribou takes reasonable measures to help protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. Nevertheless, no security system is impenetrable. We cannot guarantee that information that users of the Website may happen to transmit or otherwise supply will be totally secure.

9.     Transfer of Information to the U.S. and Other Countries

Caribou is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the United States and other countries, where you may not have the same rights and protections as you do under local law.

10.  Your Choices

Your Information

When submitting information, corresponding, making requests for information, and otherwise interacting with us and our representatives through or in connection with the Website, you generally choose what information to supply or submit, whether you wish to receive further information, and how you may be contacted. Please take care to share only such information as is needed or that you believe is appropriate. You may update, correct, or delete information about you at any time by emailing us at privacy@cariboubio.com. Note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Cookies

By placing a small file known as a “cookie” on your device, our and our third party providers’ servers passively gather information about all visitors’ use of the Website for the following purposes: statistics collection and analysis, Website optimization, analytics (as described above), market research, and maintenance of user login information. The information that we and our third party providers track with cookies includes, but is not limited to, the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the Website, your Internet protocol (“IP”) address, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the Website), how you were directed to the Website, which specific pages you access on the Website, how long you view each page, the time and date you access our Website and the total number of visitors to the Website and any portions thereof. We, and/or our third party providers, may use the information collected from cookies or similar files on your computer for security purposes (such as authentication), to facilitate site navigation and to personalize your experience while visiting the Website. This data helps us and our third party providers improve our respective product and services. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Website. For more information, please refer to http://www.allaboutcookies.org/manage-cookies/

Communications

You may opt out of receiving emails from Caribou by following the instructions in those emails. Please allow us a reasonable period in order to satisfy your request. Furthermore, if you opt out, we may still send you emails, such as those about our ongoing business relations.

11.  Your Privacy Rights

This portion of our Privacy Policy advises individuals with privacy rights under the CCPA, GDPR, the Nevada Privacy Law, and similar applicable privacy statutes of their privacy rights.

You are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information by contacting us at privacy@cariboubio.com. We may require you to prove your identity with approved identification if you request this information. Please note that we will not discriminate against you for exercising any of your rights under this Privacy Policy.

The section entitled “Collection of Information” lists the categories of personal information we have collected about persons in the preceding twelve (12) months and how that information is collected. These categories of personal information include personal identifiers, professional or employment-related information, internet, or other electronic network activity information, and transaction information, including transaction details related to your purchases through the website.

We do not, and do not intend to, sell Personal Information. We may, however, use and share personal information as is set out above in the “Use of Information” and “Sharing of Information” sections of this Privacy Policy.

You have the following rights with respect to the personal information we collect about you:

  • Request access to the personal information we hold about you;
  • Request we correct any inaccurate personal information we hold about you;
  • Request we delete any personal information we hold about you;
  • Restrict the processing of personal information we hold about you;
  • Object to the processing of personal information we hold about you;
  • Receive any personal information we hold about you in a structured and commonly used machine-readable format or have such personal information transmitted to another company. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the requested information to you;
  • If we rely on your consent as legal basis for processing your Personal Data, you have the right to withdraw that consent at any time. This includes, but is not limited, to cases where we use your Personal Data for direct marketing purposes.

Although we will do our best to honor your request, we may not be able to do so in certain situations where you data is needed or required (e.g., complying with the legal process or facilitating a transaction upon your request).

Should you wish to request the exercise of your individual rights as detailed above with regard to your personal information, we will seek to verify your identity. You will be required to submit your first and last name and email address and may also be asked to provide your telephone number or address so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.

If you are located in the European Economic Area (EEA), you have the right to lodge a complaint about how we process your personal information with the supervisory authority in your country. For more information on your rights and accordant requirements, please see the information provided by the European Union Commission at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

Please direct any rights requests or additional questions you may have regarding this Privacy Policy via email to privacy@cariboubio.com.

Do Not Track Requests

Certain state laws require that we indicate whether we honor “Do Not Track” settings in your browser. We adhere to the standards set out in this Privacy Policy and do not monitor or follow any Do Not Track browser requests.

12.  Contact Us

If you have any questions about this Privacy Policy, please contact us at: privacy@cariboubio.com