Privacy Policy

Effective as of 20 August 2024
Sections
Introduction

Babylon Labs Ltd ("Labs", "we", "us" or "our") is committed to protecting the privacy of our users, stakeholders, and business partners. This Privacy Policy describes how we use, disclose, and safeguard any personal information that we collect through our digital or online properties or services (including as applicable, our website, social media pages, marketing activities, live events and other activities described in this Privacy Policy (each separately and collectively, the "Service").

This Privacy Policy takes into account the requirements of the British Virgin Islands Data Protection Act 2021 ("DPA") and general Privacy Principles.

Please read this Policy carefully. By using, accessing, connecting to, or downloading any of the Service, you agree and consent to the collection, use, protection, and disclosure of your information as described in this Policy. If you do not agree to this Policy, please do not use, access, connect to, or download any of the Service.

PERSONAL INFORMATION WE COLLECT

We may collect the following categories of personal information:

  1. Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
    • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
    • Demographic data, such as your city, state, country of residence, and postal code.
    • Forum account data, such as the username and password that you may set to establish an online forum account on the Service, date of birth, redemption code, biographical details, photograph or picture, links to your profiles on social networks, interests, preferences, and any other information that you add to your forum account profile.
    • Communications data, such as the data we collect based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
    • Job applicant data, such as professional credentials and skills, educational and work history, LinkedIn profile page, personal website, authorization to work in the U.S., immigration status, criminal history, and other information that may be included on a resume or curriculum vitae as well as in a cover letter. This may also include diversity information that you voluntarily provide.
    • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
    • User-generated content data, such as photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
    • Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.
    • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
  2. Information from third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
    • Public sources, such as government agencies, public records, social media platforms, and other publicly available sources
    • Private sources, such as data providers, social media platforms and data licensors.
    • Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
    • Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
    • Marketing partners, such as joint marketing partners and event co-sponsors.
  3. Automatically collected data. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
    • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
    • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
    • Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through the use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

COOKIES AND SIMILAR TECHNOLOGIES

Some of the automatic collection described above is facilitated by the following technologies:

  • Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both "session cookies" that are deleted when a session ends, "persistent cookies" that remain longer, "first party" cookies that we place and "third party" cookies that our third-party business partners and service providers place. Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of cookies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including certain features and general functionality, to work incorrectly.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

  • provide, operate and improve the Service and our business;
  • personalize the Service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
  • establish and maintain your user profile on the Service;
  • facilitate your invitations to friends who you want to invite to join the Service;
  • facilitate social features of the Service, such as by providing chat or messaging functionality;
  • enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
  • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
  • communicate with you about events or contests in which you participate;
  • understand your needs and interests, and personalize your experience with the Service and our communications; and
  • provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing. We and our service providers may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Events, promotions and contests. We may use your personal information to:

  • administer promotions and contests
  • communicate with you about promotions or contests in which you participate
  • contact or market to you after collecting your personal information at an event

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

To manage our recruiting and process job applications. We may use personal information, such as data submitted to us in a job application, to facilitate our recruitment activities and process job applications, such as by evaluating a candidate for a job, and monitoring recruitment statistics.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce the terms and conditions that govern the Service; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

  • Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
  • Functionality. To enhance the performance and functionality of our services.
  • Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION:

We process your personal information based on one or more of the following legal bases:

  • Where you have agreed and consented to the processing of your personal information
  • Where processing is necessary for the performance of a contract with you, or for us or our service providers to responsibly enter into a contract
  • Where processing is necessary to comply with a legal obligation
  • Where processing is necessary for our legitimate business interests, provided your interests and fundamental rights do not override those interests
  • Where processing is necessary in order to protect your vital interests as a data subject or those of another person

The processing of personal information may be permissible under multiple of the above categories in any given case.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

  • Affiliates. Our corporate parent, subsidiaries, and affiliates.
  • Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
  • Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
  • Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
  • Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
  • Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
  • Business transferees. We may disclose personal information in the context of actual or prospective business transactions, for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Labs as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
  • Other users and the public. Your profile and other user-generated content data are visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to make your forum account profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

INTERNATIONAL DATA TRANSFER

We are headquartered in the British Virgin Islands and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

YOUR RIGHTS AS A DATA SUBJECT

By notice in writing to us, delivered to our Notice Address, you may be entitled to:

  • receive (in an intelligible form) the personal data we hold about you and any information available to us as to the source of that personal data, provided that the personal data can be disclosed without disclosing personal data of another data subject;
  • request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (where consent was the basis for processing) and there is no other legal ground for processing;
  • request the rectification of any error or omission in your personal data in our possession or under our control;
  • require us to cease processing, or not to begin processing, your personal data for the purposes of direct marketing;

We may require further information from you in order to be satisfied as to your identity, or in order to locate the information sought, and we are not obliged to provide you with personal data or otherwise address your request unless you satisfy our requirements. We will endeavour to respond to a written request within the timelines set out in the British Virgin Islands DPA.

YOUR CHOICES

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track", please visit https://www.allaboutdnt.com.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Remove or anonymize your content. You may request that the content that you posted to the Service be removed or anonymized such that your personal information will not be publicly identifiable on the Service by contacting us. We may decline to process your request as consistent with law. Please note that even if we process your request, it does not ensure complete or comprehensive removal of the content or information posted on the Service.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

OTHER SITES AND SERVICES

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Certain transactions conducted via our Services may require you to connect a compatible third-party digital wallet ("Wallet") to the Services. By using such Wallet to conduct such transactions via the Services, you agree that your interactions with such Wallet(s) are governed by the privacy policy for the applicable Wallet, and you agree that you are using the Wallet in accordance with the terms and conditions of the applicable third-party provider of such Wallet. Wallets are not maintained or supported by, or associated or affiliated with Labs. We expressly disclaim any and all liability for actions arising from your use of any Wallets, including but without limitation, actions relating to the use and/or disclosure of personal information by such third-party Wallets.

SECURITY

We employ a number of technical and organizational safeguards designed to protect the personal information we collect. These measures include encryption, access controls, and regular security audits. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

CHILDREN

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting of the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

HOW TO CONTACT US

If you have an unresolved privacy or data use concern that we have not satisfactorily addressed, please contact the data protection regulator in your jurisdiction. If you have any questions or concerns about this Privacy Policy or our data protection practices, please contact us via email at [email protected] ("Notice Address").

If you have an unresolved privacy or data use concern that we have not satisfactorily addressed, please contact the data protection regulator in your jurisdiction.