This Privacy Policy applies to information about you collected by Codonics, Inc. (“Codonics” or “we”), including through our website, www.codonics.com (the “Site”).

We have created this Privacy Policy in order to demonstrate our commitment to privacy including, to the extent applicable, the European Union General Data Protection Regulation (GDPR). Your right to privacy and data security is a primary concern. This Privacy Policy sets out the basis on which any information we collect from you, or that is provided to us, will be processed by us.

By visiting the Site or using our services, you accept the terms and practices described in this Privacy Policy, including:

• What information do we collect from our users?
• How do we use your information?
• How do we share your information?
• How do we protect your information?
• Do we collect personal information from children?
• How can you access your information?
• Your rights (EEA relevance)
• Application and Revisions

What information do we collect from our users?

We receive and collect the following information from users:

Information You Give Us:

We collect and store information that you give us when you visit this site, submit an employment application, and otherwise use our services, including:

• Name, address, e-mail address and other demographic information (such as age, gender, country and preferred language) when you contact us to request information;
• Payment data such as your payment instrument number (credit card or other) and security information associated with your payment instrument;
• Content of your communications with us, including with respect to your interests in our products and any other information your provide us through your communications;
• Any information you provide when you complete and submit an employment application; and
• Information you provide related to product registration.

Information Collected When You Use Our Services:

We collect information through the use of technology (e.g. cookies, web beacons) when you visit our website or social media sites, use our services, open our e-mails, or view our advertisements. Please review our Cookie Policy for more details.

Information From Other Sources:

We may obtain information about you from our affiliated companies, business partners, and other publicly or commercially available sources (e.g. data aggregators). This information may include: demographic information, credit information, and purchasing history.

How do we use your information?

We will generally only collect personal information from you when we need this information in order to provide a service to you. In such instances, failure to provide your personal data may mean that we are not able to provide services you requested.

In particular, we use the information we collect to:

• provide the products and services you request;
• administer and manage our website;
• respond to user support requests; analyze, customize, and improve our content, products, and services;
• communicate with you by phone, e-mail, regular mail, text message, and mobile devices about our products;
• develop and display advertising tailored to your interests on our website and other sites, and to determine the effectiveness of our advertising; and
• enforce our privacy policy, the terms and conditions of use that govern this website, and other agreements, as well as to comply with legal obligations, and to otherwise manage our business.

We do not perform any automated-decision activities, including profiling activities, where your personal data is processed by automated means.

Direct marketing

Where we process your personal information for direct marketing purposes, you may object to our processing your personal data in this way at any time. If you do so, we will log your objection, stop processing your data for direct marketing purposes, and we will not contact you again. (See also “How can you access your information?” below).

Your consent

Before collecting any personal information from you, we will generally ask you for your consent. We may request this consent in varying forms, such as by asking you to tick a box on a form (or when visiting our website) or by asking you to provide a written or oral statement.

You may withdraw your consent at any time, by contacting us at data-privacy@codonics.com or by using the contact details provided below (see “How can you access your information?”).

Please note, however, that withdrawing your consent will not affect the lawfulness of processing based on the consent you gave prior to withdrawal.

Processing your data for our legitimate interests

In some cases we will process your personal data for our legitimate interests, rather than seeking your consent. This is largely so that we can efficiently provide you with services and information about our services and products without having to seek individual consent for everything we do (or where in some cases it might not be possible for us to seek your consent). We will, however, always provide you with information on our data processing activities on request and from time to time.

Before undertaking such processing, we will consider your rights and freedoms and will only commence such processing where we do not think your rights will be infringed.

How do we share your information?

We share or disclose your information only as described in this policy or at other instances after we obtain your freely given, specific, informed and express consent.

Business Partners & Affiliates.

We share information with affiliates and companies that we partner with to offer services, products, and promotions when you elect to purchase those products or services or engage in those promotions (e.g. distributors, sales channels).

Third Party Service Providers.

We may use third parties to perform business functions on our behalf, including order fulfillment, shipping, processing credit card payments, user service, marketing, provision of IT services, legal and other outside consultancy services, and records maintenance. They are given access to information to perform these functions. We require that they protect this information and do not authorize them to use that information for any other purpose.

Other Situations

If Codonics is involved in a merger, acquisition, or sale, your information could be among the assets transferred or disclosed. We will protect your information during this process and give you notice through this website before your information is transferred. We may also share information: (1) where permitted by law; (2) to comply with applicable law or requests from public authorities; (3) to address fraud, security, or technical issues; (4) to enforce our privacy policy, the terms and conditions of use that govern this website and our services, and other agreements; and (5) to defend and protect the rights, property, or safety of Codonics, our users, or the public where required or permitted by law.

We may combine personal and non-personal information we obtain with other information we obtain from third parties. We may transfer your information to our business partners and affiliates for this purpose. We may also share aggregated information that cannot be used to identify you with third parties.

Where we store your personal data

We are based in the United States and are globally active, with activities located in various jurisdictions, which use service providers based in a number of locations worldwide. We may therefore transfer your personal data to, or store it in a number of destinations. Data may be stored outside of, or transferred to, or from the European Economic Area (“EEA”). In some cases, your personal data will be stored in or transferred to jurisdictions where data protection laws are not as stringent as the applicable laws under the EEA regime. Where we have to transfer your personal data to any such jurisdictions, we will use appropriate approved safeguards or we will seek your explicit consent to the extent required by applicable law.

Period for which we store your personal data

We will ensure that the period for which we store your personal data is limited to a strict minimum. We will store your personal data for no longer than is necessary for the relevant purpose and for legal compliance purposes. For further information on how long we will store your personal data in any particular case, please do not hesitate to contact us.

How do we protect your information?

Codonics works to establish appropriate technical, administrative, and physical procedures to protect personal information from loss, misuse, or alteration. We maintain the servers that store your information in a facility with restricted access. We also restrict access to information to those employees and third parties who need access to perform their business functions, and they may be disciplined or terminated for not protecting the confidentiality of your information.

Where information is provided to us via our websites, for some of our websites, the information passed between your browser and our system is encrypted with secure sockets layer technology to create a protected connection between you and our website to ensure confidentiality. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. We will use commercially acceptable means to protect your personal data, and we may strengthen our data protection measures from time to time taking into account technology changes, but we cannot guarantee its absolute security.

Do we collect personal information from children?

Our services are not intended for use by children, and we do not knowingly collect information from children under the age of 13 and will delete such data upon discovery. [Should we require personal data pertaining to children for the purpose of providing a service, the consent of an adult with parental responsibility for that child will be required.]

Third Party Sites

Our website may contain links to websites controlled by third parties, including distributors and sales channels, and we may allow third parties to place advertisements on our website. We are not responsible for the privacy practices of websites or other services operated by third parties or for the privacy practices of any third party. Once you leave our website by a link to a different website, access a third party application, or click on a third party offer, we do not have any control over that other website and you should check the applicable privacy policy of the third party or advertiser site to determine, among other things, how they will handle any personal information they collect from you.

How can you access your information?

We take steps to keep your information accurate. You may contact us by any of these methods to update or correct your information or change your communication preferences:

• Follow the directions in a marketing e-mail or direct mail or mobile communication that you receive from us;
• By sending an e-mail with your current contact information to info@codonics.com, calling +1.440.243.1198, or sending a letter with your current contact information to Codonics, Inc., Attn: Communications, 17991 Englewood Drive, Middleburg Heights, Ohio.

If you choose to not provide information to us, doing so may prevent you from using our services or features of the website. If we have already provided your information to third parties before you changed your preferences, you may need to contact those third parties directly. [To the extent it is reasonably possible Codonics will contact these third parties, or at least provide data subjects with the third parties’ contact details upon request, to facilitate data subjects’ control over their personal data.] To the extent permitted by law, certain operational communications (for example, confirmation of delivery address) are not subject to the opt-out process.

If you request us not to use personal information in a particular manner, we will adopt reasonable measures to observe your request but we may still use or disclose that information if:

• you do not provide us with adequate time to address your request;
• we subsequently notify you of the legitimate purpose of our use of your personal information and why we believe that this purpose overrides your objection;
• we believe that the use or disclosure is reasonably necessary to assist a law enforcement agency or an agency responsible for government or public security in the performance of their functions; or
• we are required by law to disclose the information.

Your rights (EEA relevance)

Under GDPR, to the extent applicable to the information about you we collected or process, you have a number of rights:

Access.

You may contact us at any time in order to request access to the personal information we hold about you. We will confirm whether we are processing your personal data, provide details of the categories of personal data concerned and the reasons for our processing. We can also provide you with a copy of your personal information on request.

Rectification.

If the information we hold appears to be inaccurate we will not use it, and not allow others to use it, until it is verified. You can ask us to correct or complete your personal data by contacting us at any time. To the extent reasonably feasible, we will inform anyone who has received your personal data of any corrections we make to it.

Restriction.

In certain circumstances, it may be possible to require us to limit the way in which we process your personal information (i.e., require us to continue to store your personal data, but not otherwise process it without your consent). Such circumstances include:

where you think the data we hold about you is inaccurate, processing can be restricted while it is being rectified;
where you object to our processing, (which is being carried out on the grounds that it is necessary in the public interest or for our legitimate interests) processing can be restricted while we determine whether such grounds override your interests
where processing is unlawful but you oppose the erasure and request restriction of your data instead; and
where we no longer need the personal data but you require the data in order to establish, exercise or defend a legal claim, our processing can be restricted.

Erasure.

You may ask to have your information deleted or removed. We will try to do so promptly, and, to the extent reasonably feasible, we will inform anyone who has received your personal information of your request. However, we must keep track of certain transaction information, such as past purchases and similar information, for legal compliance purposes, so we may not be able to fully delete your information in certain circumstances.

Receiving your personal data.

You may also ask us to send you the personal data we hold on you in an electronic, structured and user-friendly format, or you may ask us to send this data to another person. Please note that if you choose to ask us to send your personal data to you or another party, this may impact our ability to provide the products and services you requested.

Object.

Where we are processing your personal information without your consent to pursue our legitimate interests, you may object to us processing your personal data. In particular, where we are using your personal data to contact you for marketing purposes, you may object to such processing at any time.

Complaints.

If you are located in the EEA and you believe that our processing of your personal data is in breach of data protection law, you have the right to lodge a complaint with the relevant data protection supervisory authority in the country where you are based or any place in the EEA where you believe the infringement has occurred. You may also contact us at any time if you wish to complain about our processing of your personal data.

For any of the requests listed above, please contact us at data-privacy@codonics.com or using the contact details above (see “How can you access your information?”). We will make reasonable efforts to respond promptly and at the latest within one month. Our response to such requests may be limited to information under our direct control.

Application and Revisions

This Privacy Policy was last updated on June 7, 2018.

If you visit this website or use our services, you accept the practices described in this Privacy Policy, which is incorporated as part of the Terms of Use governing this website. We may change or add to this Privacy Policy from time to time. When we do, we may notify you the next time you visit and we will post the revised Privacy Policy here. Your use of the Site after changes to this Privacy Policy have been posted constitutes your knowledge and acceptance of those changes (i.e., that the changes may be applied to the information we collect from and about you). You should check the Site frequently for changes. We will not make material changes to the Privacy Policy that are less protective of your information without first sending you an e-mail to the e-mail address you most recently provided and posting notice of the changes on this site.