Phage.AI

Privacy Policy

Privacy Policy - app.phage.ai

1. Introduction

On the website of https://app.phage.ai/ (“app.phage.ai”) we want to provide you the best possible access to phage database that allows you to enter phage sequences, share phage sequences, and download phage sequences that are available after you create an account on app.phage.ai by providing your email address and creating a password, and after you accept the current policies of app.phage.ai. As you provide us with your personal data, one of our top priorities will always be your privacy and the security of your personal data.

So we want to explain clearly how we collect, store, share and use your personal data, and how we can control and determine the preferences you have when sharing your personal data.

This is the purpose of this Privacy Policy (“Policy”), which contains detailed information on this subject.

2. Information on the Policy

This Policy sets out the most important information concerning your relationship with https://app.phage.ai/, as part of your personal data.

We may periodically develop new offers on website. If the introduction of new or additional offers changes the way we collect or process your personal data, we will provide you with additional information, terms or conditions. Unless otherwise stated, new or additional services introduced will be subject to this Policy.

The purpose of this Policy is to:

  • ensure that you understand what personal data we collect with your consent, why we collect and use it and to whom we share it;
  • explain how we use the personal data you provide to us to use the website of app.phage.ai with pleasure; and
  • explain your rights and preferences with regard to the personal data we collect and how we protect your privacy.

We hope this will help you understand our privacy commitments. If you have any questions or concerns, please contact us:

PhageAI S.A.
ul. Płocka 35/43,
93-134 Łódź
Poland

E-mail address: rodo@phage.ai

3. Your rights and preferences: Control and choice

You may be aware that the new European Union law, called the General Data Protection Regulation or “GDPR”, grants individuals certain rights with regard to their personal data. The rights granted to natural persons shall, to the extent possible and except where limited by the applicable law, be as follows:

  • the right of access – the right to be informed and to request access to personal data processed by us;
  • the right of rectification – right to request that personal data are rectified or updated if they are inaccurate or incomplete;
  • the right to erasure – right to request erasure of personal data;
  • the right to restriction – right to request that we stop processing all or part of your personal data temporarily or permanently;
  • the right to object:
  • the right to object, at any time, to the processing of personal data by us on grounds relating to specific situations;
  • the right to object to the processing of personal data for the purposes of direct marketing;
  • the right to data portability – the right to request an electronic copy of personal data or to transmit them for use by third parties; and
  • the right to refuse to be the subject of automatic decisions – the right not to be subject to decisions based solely on automated decision-making, including profiling, where the decision in question is likely to produce legal effects for the user or to have similar effects.

In order to exercise these rights, we provide contact details:

PhageAI S.A.
ul. Płocka 35/43,
93-134 Łódź
Poland

E-mail address: rodo@phage.ai

If you have any questions about your privacy, rights or enforcement, please do not hesitate to contact us. We will respond to your enquiry within a reasonable time after your identity has been verified. If you are not satisfied with the way we use your personal data, you may also contact the Polish Data Protection Authority and file a complaint.

4. How we collect personal data

We collect personal data on the following occasions:

1. When you create an account – we will collect certain personal data, such as your e-mail address and username.
2. When you update your profile within your account – we will collect certain personal data, such as first and last name, biography and avatar image (if applicable), affiliation, as well as your degree and the university you are associated with.
3. When you use the website app.phage.ai – we collect personal data about your use of the website, such as the phages and projects you view and the time you spend on the website, your last login date, date of account registration and date of leaving from the platform, your IP address as well as membership to one or more user groups i.e. Admin, Expert and Moderator and as well as all bacteriophage (genomic sequences) and meta-data that you upload to the website using a form or API.

We use anonymized or aggregated data for purposes such as, research, data analysis, improving the website and developing new features and options within the website and as input to our marketing and sales strategy.

5. Personal data we collect

The following tables list the categories of personal data we collect and use about you:

Personal data collected when you create an account:

  • Correspondence data: These are the personal data you provide in order to create an account and in update profile form. These include your e-mail address, your first and last name (and, if you provide us with your details, your biography, avatar image, affiliation, degree and the university you are associated with).

Personal data collected when using the website:

  • Data concerning use of the website: This is personal data collected when using the website and may include:

Data about your interactions within the website, including a detailed description of the queries sent, their date and time, data about the content viewed, your last login date, date of account registration and date of leaving from the platform, as well as membership to one or more user groups i.e. Admin, Expert and Moderator, your IP address as well as all bacteriophage (genomic sequences) and meta-data that you upload to the website using a form or API.

Technical data that may include your URL, cookie data, your IP address, the types of devices you use to access or connect to the website, your unique device ID, device data, type of network connection (e.g. Wi-Fi, 3G, LTE, Bluetooth) and service provider, network and device performance, browser type, language, digital rights management data, operating system. Further information on the technical data we process is available below.

6. How we use personal data

When you use or interact with a website, we may use a variety of technologies to collect information about you for a variety of reasons. The following is a table showing the reasons why we process your personal data, the associated legal basis that legally enable us to process your personal data, and the categories of personal data we use for these purposes:

Reasons why PhageAI S.A. processes your personal data (“Purposes”):

  1. To enable phage sequence input, phage sequence sharing, and download phage sequences available on app.phage.ai website, to response to inquiries made through the website and to provide and improve the use of the website.
  2. To understand how you access and use the website to provide technical functionality and to analyse how you use the website, including your interactions with advertisements and products made available directly or through links or offered through the website.
  3. To communicate with you on issues related to the website.
  4. Internal administrative purposes including statistical purposes and to prepare statistics and strategies for marketing and sales purposes.
  5. For direct marketing of products and services (Newsletter).

Legal basis for processing the abovementioned data, accordingly:

  1. Legitimate interests.
  2. Legitimate interests.
  3. Legitimate interests.
  4. Legitimate interests.
  5. Your consent.

Categories of personal data used for abovementioned processing purposes, accordingly:

  1. Contact details and Data concerning use of the website.
  2. Data concerning use of the website.
  3. Data concerning use of the website.
  4. First and last name, biography, affiliation, degree and the university, Data concerning use of the website.
  5. Identification data provided in the form for sending the Newsletter, e-mail address, name and surname.

7. Sharing of personal data

Information we may share:

  • Suppliers and others: We use technical service providers who may operate the technical infrastructure needed to respond to our requests through the website, in particular providers who host, store and maintain the website, its content and the data we process, and who manage it.
  • Academic researchers: Your personal data used in activities such as statistical analysis and academic research will only be made available in a pseudonymized form. We will share your personal data if we believe in good faith that our legal obligations require us to do so, or in response to important legal processes such as an arrest warrant, court order or subpoena.
  • Law enforcement and data protection authorities: Your personal data will also be shared if we believe in good faith that it is necessary for our own purposes or for the legitimate purposes of an outside party in connection with national security, law enforcement, legal disputes, criminal investigations, the protection of the safety of any person or the protection of against death or personal injury, provided that we consider that such interests take precedence over the fundamental rights and freedoms for which the protection of your personal data is required.
  • Purchasers of our business activities: Your personal data will be disclosed if we sell or agree to sell our business to a purchaser or potential purchaser. In such a situation PhageAI S.A. will continue to ensure the confidentiality of your personal data and will send an appropriate notification before your personal data is transferred to the buyer or becomes subject to the provisions of a different Privacy Policy.

8. Retention and erasure of data

We retain your personal data as long as necessary to provide the website and for legitimate and necessary our legal purposes, such as maintaining productivity, making decisions about new features based on data, and complying with legal obligations. Your personal data will be stored as long as you use the website and, if you create an account, as long as you delete it and request deletion of your personal data.

Upon request, we will delete or anonymize your personal data so that it no longer serves your purpose to identify you, unless we are legally authorized or required to retain certain personal data, including in the following situations:

  • if we are required to retain your personal data in order to comply with legal, tax and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
  • to protect our legitimate goals, such as preventing fraud or ensuring the security of our users.

9. Data transfer to other countries

We may transfer your data to a third country in connection with our use of IT systems using cloud services, however, the entity providing the above-mentioned the service is considered by the European Commission to be an entity providing an adequate level of protection, and moreover, if the provider provides cloud services to a third country that does not have an adequate level of protection – it provides adequate and appropriate safeguards. You have the option of obtaining a copy of the transferred data or where the data is available.

10. References

We may display third-party advertising and other content that links to third-party websites. We cannot control and are not responsible for the content or privacy practices of third parties. When you click a link or advertise an outside party, remember that you are leaving the website and that any personal data you provide will not be governed by this Policy. Please refer to the third party’s privacy policy for how we collect and process your personal data.

11. Security of personal data

Our goal is to protect the personal data of our users. We implement appropriate technical and organizational measures to protect your personal data, however, remember that no system is ever completely secure. We have implemented various policies, such as pseudonymization, access and storage policies, to protect against unauthorized access and unnecessary storage of your personal data on our systems.

12. Cookies

A cookie is a text file that is stored on your device when you visit a website. Cookies help website providers to recognize your device. Find out more about cookies at: www.allaboutcookies.org or www.youronlinechoices.eu.

The term “cookies” actually describes a wide range of technologies, including:

  • pixel tags (transparent graphic tags on a website or in an e-mail that generate information that records when you visit a website or read an email),
  • mobile device identifiers, and
  • the website’s data storage function, which is used by computer software or mobile devices.

The term cookies will be used in this Policy to describe all such technologies, but we will try to provide you with detailed information about them to enable you to make informed choices about the settings of cookies.

Cookies have different tasks, such as successfully navigating between pages, remembering preferences and generally improving the user experience. They can also help you choose the right advertisements for you when you browse the web, according to your preferences and interests.

There are several different categories of cookies, including:

Session and persistent cookies

Session cookies are cookies that expire when you close your browser; and

Persistent cookies are cookies that remain on your device for a period of time or until you delete them.

Own Cookies and Third Party Cookies

Own Cookies – These are cookies that are placed by us or by an external entity on request through the website you are visiting at the time;

Third-party cookies – These are cookies that are placed by an entity other than the website you visit. If you visit the website https://phage.ai/ or https://app.phage.ai/ and another entity places cookies via this website, this cookie will be a cookie of an external entity.

Necessary cookies

These cookies are necessary to enable the use of our website. Without these files, some of the website’s services may not be provided.

In summary, these cookies allow you to use the features you choose and allow you to share our products and services.

Performance related cookies

These are cookies that provide us with information about how visitors use our services, such as which pages are visited most frequently, information about the errors that appear most frequently on the pages. These cookies collect information about the pages you visit in an anonymous form. All the information collected in these files is combined and made anonymous. They are only used to improve our services.

This category includes an online analysis which uses cookies to collect data to improve the performance of the website. They can be used to test projects and to provide a customised form. Cookies used by providers of behavioural/directed advertising are excluded.

Functionality related cookies

These files allow the website to save user settings (user name, language, location) and help streamline and better match services. These cookies also allow you to remember any changes you make, such as changes in the size and font of the text and other personally identifiable elements of the website. The data collected by these files may be anonymized and may not be used to track activities on other sites.

These cookies allow you to remember your choices in order to improve your experience.

If the same cookie is used for redirecting purposes, it must also be included in the category of ‘cookies related to advertisements and their recipients’. This may also include cookies that are used for a specific purpose, but if this feature includes cookies used by behavioural/directed advertising providers, they must also be included in the category “cookies related to ads and their recipients” as well as in this category.

Cookies related to advertisements and their recipients

These cookies are used to provide you with ads that are more relevant to your interests. They are also used to limit the frequency with which you see the same advertisement and to evaluate the effectiveness of advertising campaigns. They are usually placed by advertising networks with the consent of the website operator. They remember your visit and send this information to organisations such as advertisers. Often these files are linked to the functionality of the sites they host.

These cookies collect information about your online habits in order to better tailor advertising to your interests.

Management of cookie settings

Browser cookies

You may withdraw or modify your consent to the use of cookies at any time. If you do not wish to receive cookies, you can change your browser’s settings to accept, block, and delete cookies. To do this, follow the instructions in your browser (usually in the settings on the “Help”, “Tools” or “Edit” pages).

Please note that if you set your browser to block cookies, you will not be able to use the full functionality of this website. More information is available at www. allaboutcookies.org.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer to help the website analyse how visitors use the website. 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 servers. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators 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 this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en.

This guarantees anonymized data collection by masking the last part of your IP address.

Further information concerning the terms and conditions of use and data privacy can be found at www.google.com/analytics/terms/gb.html

13. Newsletter

Newsletter data

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Article 6 Section 1 letter a GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Article 6 Section 1 letter f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

Legal basis

The data is processed based on your consent (Article 6 Section 1 letter a GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.

Storage period

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Article 6 Section 1 letter f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

Your newsletter data will be processed by MailChimp, a newsletter provider owned by Rocket Science Group, LLC, 675 Ponce De Leon Ave NE # 5000, Atlanta, GA 30308, USA. MailChimp is committed to complying with EU data protection requirements. Please find more information in the privacy policy of MailChimp at: https://mailchimp.com/legal/.

14. Changes in the Privacy Policy

We may change the provisions of the Policy from time to time.

If we make material changes to this Policy, we will notify you of such changes clearly and in a manner that is appropriate to your circumstances, for example by displaying a clearly visible notice on our website or by sending you an e-mail. In some cases, we will notify you in advance.

We therefore ask you to read these notifications carefully.

15. Contact details

Thank you for reading our Privacy Policy. If you have any questions regarding this Policy, please contact us:

PhageAI S.A.
ul. Płocka 35/43,
93-134 Łódź
Poland

E-mail address: rodo@phage.ai