Emulate, Inc. Privacy Policy

Emulate, Inc. Privacy Policy

This is the privacy policy (“Privacy Policy”) of Emulate, Inc. (“Emulate,” “we,” “us,” and “our”).

Please review this Privacy Policy carefully. By using our Website (as defined below), you acknowledge that you accept this Privacy Policy. If you do not accept this Privacy Policy, you may not access the Website. 

This Privacy Policy explains how we collect and use your Personal Information (as defined below) when you access or interact with our websites, including those in the domain emulatebio.com and moxicentral.com and other websites and mobile applications operated by Emulate (collectively, the “Website”), and the choices you can make about that Personal Information. Because your privacy and trust are important to us, we are committed to responsibly handling and protecting any Personal Information you provide to us through our Website.

What is Personal Information?

“Personal Information” means any information relating to an identified or identifiable natural person, such as first and last name, address, email address, company and department, and/or other types of contact information. An identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

Visitors to the Website may use many of the Website’s features without revealing any Personal Information, however in some instances we may request that users provide certain Personal Information to facilitate further communications. In such instances we collect, use, disclose and transfer and store Personal Information to the extent necessary for certain business purposes as detailed in this Privacy Policy.

What Personal Data Do We Collect and How Do We Collect It?

When accessing or interacting with our Website, you may be asked to provide us with certain Personal Information. For example, in order to access certain portions of our Website, request information about our products or services or request user support, you may be asked to provide your contact information (e.g., name, institution/company and department, phone number, email address, zip or postal code, etc.). You may be asked to provide Personal Information in order to create an account on our Website or to submit a user support request. Emulate does not collect, store or transmit credit card or payment information. 

Not all of the information that we collect about you will always come directly from you. For example, it may come from the institution/company with which you are employed if it is a customer/user of our products and/or services.

To improve your experience on our Website and/or to facilitate our efforts to market our products and services, we may use automatic data collection technologies and/or web-based automated marketing solutions  to collect certain non-Personal Information about your equipment, browsing actions/patterns and online activities (i.e., behavioral tracking), including:

• Details of your visits to our Website, including traffic data, location data, logs (e.g., length of visit and number of page views), and other communication data and the resources that you access and use on the Website; and
• Information about your computer and internet connection, including your IP address, operating system, and browser type. 

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website or certain aspects of our Website may not function properly. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. 
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, you may be unable to access certain parts of our Website or certain aspects of our Website may not function properly. 
• Web Beacons. Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Emulate, for example, to count users who have visited those pages and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

We do not collect any Personal Information automatically, but we may tie the non-Personal Information described above to Personal Information about you that we have collected from other sources or that you provide to us.

With respect to third-party technologies used our Website, it is important to note that we do not control the tracking technologies those third parties use nor do we control how such third parties will use the information they obtain from those tracking technologies. These third-party technologies (such as Google Analytics, for example) may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our Website. The information collected by these third-party technologies may be associated with your Personal Information or about your online activities over time and across different websites and other online services. These third-party technologies may use this information to provide you with interest-based (behavioral) advertising or other targeted content. To learn more about how Google Analytics, in particular, collects and processes this information, please visit the following website: www.google.com/policies/privacy/partners titled “How Google uses data when you use our partners’ sites or apps”. If you would like to opt-out from the use of your information by Google Analytics, you may use Google Analytics’ opt-out browser add-on designed for this purpose located here: https://tools.google.com/dlpage/gaoptout. 

If you receive promotional or informational emails from us, you may opt out of these communications at any time by using the “unsubscribe” link at the bottom of all emails.

How Do We Use Personal Information? 

We may use Personal Information we collect for the following business purposes:

• To improve and market our products and services; 
• To respond to general inquiries or provide technical and user support and training; 
• To communicate with you regarding any account you establish on our Website (including specific functions such as successful account creation or password resets) or otherwise provide you with news, marketing and event communications about our products and services (which you can opt out of by following the unsubscribe instructions included in electronic communications or by sending an email to legal@emulatebio.com); 
• To personalize your experience and to make recommendations regarding our products and services;
• To verify your identity; 
• To comply with legal obligations, including the prevention, detection and/or investigation of fraud, abuse, security incidents and any harmful activity; and 
• To ensure the adequate performance of any contract we may have with you.

Do We Share Personal Data? 

We may disclose your Personal Information to third parties under the following circumstances:

• We may disclose your Personal Information to our contractors, service providers and other partners (including without limitation, hosting and platform providers), who support our Website and/or our business and/or who process payments on our behalf. We may also share your Personal Information with service providers who provide data analysis services, customer relationship management solutions and B2B marketing automation solutions so that we can effectively manage our relationship with you as a customer and inform you about our products and services that may be of interest to you.
• We may disclose your Personal Information when we believe in good faith that such sharing is reasonably necessary to investigate, prevent or take action regarding possible illegal activities or to comply with legal process. 
• We may disclose your Personal Information in situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or our user agreements or to respond to claims of violation of the rights of third parties and/or to protect the rights, property and safety of Emulate, our employees/agents, our users or the public.
• We may disclose your Personal Information to third parties: (i) in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets and (ii) in connection with a merger or other acquisition or if substantially all of our assets are acquired by a third party, in which case Personal Information will be one of the transferred assets.

Where Do We Store and Process Personal Data? 

Emulate may transfer, store and process your Personal Information with service providers based in the United States. If you visit our Website from outside the United States, your Personal Information will be transferred to the United States. You acknowledge that United States laws may differ from, and not offer the same level of data protection as, the laws applicable to your country of residence. 

How Do We Secure Personal Data? 

We are committed to protecting the security of the Personal Information collected, and we take reasonable physical, electronic, and administrative safeguards to help protect such data from unauthorized or inappropriate access or use. It is your responsibility to protect the confidentiality of your passwords, account information, and any other access features associated with your access or use of our Website and to adhere to any applicable terms of use or other contract between us and you or your institution/company.

How Long Do We Retain Personal Data?

We generally retain Personal Information for as long as needed for the specific business purpose(s) for which it was collected. In some cases, we may be required to retain Personal Information for a longer period of time based on laws or regulations that apply to our business or for other necessary business purposes.

What Rights Do You Have to Access and Control Your Personal Data?

You have the right to request access to your Personal Information we have on file by contacting us at legal@emulatebio.com. In order to comply with your request, we may ask you to verify your identity. We will fulfill your request by sending you a copy of your Personal Information electronically.

In addition, we will honor any request you make to update, correct or delete your Personal Information or suspend processing of your Personal Information, subject to and in accordance with our rights and obligations under applicable law. Please contact legal@emulatebio.com with any such requests.

We respect your right to access and control your Personal Information and, as such, will make reasonable efforts to respond promptly to any lawful requests described in this section in accordance with applicable laws. If you are not satisfied with the way that Emulate manages your Personal Information, you have the right to make a complaint to the applicable data protection authorities.

Links to Third Party Websites

Our Website may contain links to third-party websites, or may give you access to applications, software, or products provided by third parties. Please understand that those third-party websites and products may have different terms of use and privacy policies, and that Emulate does not control and is not responsible for the content of such websites or the privacy practices of such third parties. We are also not responsible for the terms of use you may be required to agree to in order to use such third-party websites and products. As such, you should review any applicable third-party terms of use and privacy policies prior to using those third-party websites and products. 

User Forums

If you use a user forum on the website, you should be aware that any personally identifiable information you submit there can be read, collected or used by other users of these forums and could be used to send you unsolicited messages. Emulate is not responsible for the information you choose to submit in these forums.

Children 

We do not knowingly collect or solicit Personal Information from children under the age of 13. If we learn that we have collected Personal Information from a child under the age of 13, we will delete that information as quickly as possible.

Do Not Track 

Our Website does not support Do Not Track at this time. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit www.donottrack.us.

Special Notice to California Residents

Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. Emulate does not share any information about you to third parties for marketing purposes, however, to make such a request, please contact us using the contact information provided in the “How to Contact Us” section below and provide us with your name, address and email address. We will respond to you within thirty (30) days of receiving such a request. Privacy Policy for Residents of the People’s Republic of China

If you reside in the PRC, [additional jurisdiction specific terms] will apply to the processing of your personal information.

Additional Privacy Policy for European Union (EU), European Economic Area (EEA), and United Kingdom (UK) Residents

Our European privacy policy addendum describes how Emulate protects and uses data provided by web site visitors and Emulate contacts from the European Union (EU), European Economic Area (EEA), and United Kingdom (UK).

Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Website, and in the case of any material changes, we will notify you by email or other means before such material changes take effect. Your continued use of the Website after the date the changes take effect will be subject to the revised Privacy Policy.

How to Contact Us

If you have any questions, comments or notices regarding these Terms, you may contact us in one of the following ways:

Email: legal@emulatebio.com 

Mail
Emulate, Inc. 
Attn: Legal Department 
27 Drydock Avenue, 5th Floor 
Boston, MA 02210 USA

Additional Information for EU Residents

The Personal Information you provide to us includes “personal data” as defined by and subject to any national law of an EU member state adopted pursuant to General Data Protection Regulation (EU) 2016/679. Emulate is the “controller” of the personal data you provide to us. As discussed above, we will transfer your personal data to the United States where our offices are located. We will only transfer your personal data to the United States through the use of appropriate safeguards.

We process personal data as necessary to pursue our legitimate interest to provide our services to you. You have the right to access a copy of your personal data, correct inaccuracies in your personal data, request the erasure of your personal data and restrict the processing of your personal data. For more information about how you can access, rectify and erase your personal data, please contact us at the contact information provided in the “How to Contact Us” section above. In addition, you have the right to lodge a complaint with a supervisory data protection authority. 

Version Control 

Version 1: Effective June 12, 2018 
Version 2: Effective December 17, 2018 
Version 3: Effective April 4, 2019 
Version 4: Effective May 9, 2019 
Version 5: Effective September 16, 2019 
Version 6: Effective October 1, 2020
Version 7: Effective June 22, 2021

Version 8: Effective May 23, 2022

Privacy Policy for Residents of the People’s Republic of China

Emulate is the personal information processor of your personal information for the purposes of the Site.

Personal Information Collection and Purposes of Use

Emulate will collect your personal information for the purposes described below, including: 

1. Account registration: As part of the registration process, you may be asked by us to provide certain required personal contact information, including your name, email address, mobile number, company name, city you live in.
   
2. Processing your purchase order and sample request: When you purchase our products or request samples though our Site, we will collect your personal information, including your account, name, shipping address, email address, mobile number, payment information (i.e., credit card information), invoice information, occupation and institution, and other information concerning your order. Meanwhile, for the purpose of processing and fulfilling the order, we will collect from you the relevant personal information including recipient’s name, shipping address, postal code, mobile number, and where applicable, we may share such information with third party logistics companies or service providers for the order fulfilment purposes. The payment information and invoice information may be considered as sensitive personal information.
   
3. Improving products and services and conducting data analysis and targeted marketing: When you visit our Site, we will directly or indirectly, collect information about your use and navigation of our Site, such as your IP address, location, device identifiers, your operating system and browser type, and information about the Site pages you visit, by use of cookies or other tracking technologies. We may also collect information about how your device has interacted with us, including the pages accessed and links clicked, how you navigate to and from the Site and its content (such as how you scroll over the Site and its content, which parts you click and how long you spend on each page), your preferences, the products and/or services that you have viewed or searched for, crashes and download errors and response times. The collection and use of such information about your use and navigation of our Site are primarily for data analytical purposes, and subject to your consent, such information about your use and navigation of our Site may also be used for our targeted marketing purposes. Such information about your use and navigation of our Site may be considered as sensitive personal information. If you would like to manage the targeted marketing material sent by us, please contact us at marketing@emulatebio.com.

4. Providing posting feature on our user forum: When you post contents or make comments on our Site, we will collect the information you post or comment on, and display your account, profile photo and content you post or comment on. To comply with applicable law, we will collect necessary personal information from you to verify your personal identity.
   
5. Personal information that you voluntarily provide to us:
   
   
   • You may choose to provide additional personal information to us, so as to gain better customer experience when using the Site and our products and services. Such additional personal information includes your job responsibility, department, industry, development stage, focused products.
     
   • We will collect and process other personal information that you voluntarily choose to disclose to us.

6. In addition, in accordance with relevant laws, regulations and national standards, we may collect and use your relevant personal information without obtaining your authorization and consent under the following circumstances:
   
   
   • Where it is required to conclude and perform a contract to which you are a party;
     
   • Where it is required to perform statutory obligations or legal duties;
     
   • Where it is required to respond to public health emergencies, or protect the life, health and property safety of natural persons in emergencies;
     
   • Where personal information is processed to a reasonable extent for the purposes of news report, public opinion supervision and other acts for public interest;
     
   • Where personal information has already been made public by your own or through other legitimate channels, and processing of such personal information is done pursuant to applicable laws and to a reasonable extent;
     
   • Where personal information has already been made public by your own or through other legitimate channels, and processing of such personal information is done pursuant to applicable laws and to a reasonable extent;
     

If you provide any personal information for the purposes as described above on behalf of any other person (for example a third-party recipient’s shipping address and mobile number), you should ensure that you have obtained his/her express consent or authorization to share his/her personal information with us for the purposes described in the Privacy Policy and the People’s Republic of China (PRC) Policy including but not limited to enabling us to share his/her personal information with third party logistics companies or service providers for processing purchase order, and where necessary, sharing his/her personal information with our affiliated companies located within or outside of China.

Processing of Sensitive Personal Information

Your personal information that is collected and processed by us may include sensitive personal information. Sensitive personal information refers to personal information that, once divulged or illegally used, may easily cause harm to the dignity of natural persons or endanger personal or property safety. According to the services you actually use, your sensitive personal information processed by us may include payment information, invoice information, and information about your use and navigation of our Site, etc. It is necessary for us to process your sensitive personal information in order to provide the specific services to you and for other purposes described in this PRC Policy. We will process your personal information (including sensitive personal information) in a way that has the least impact on your personal rights and interests (for example, grant access to personal information to necessary personnel only, use encryption technologies during transmission and storage of sensitive personal information when necessary, conduct personal data protection security impact assessment). 

You agree that we can process your sensitive personal information for the purposes stated in this PRC Policy and in accordance with its provisions. If you do not want us to process your sensitive personal information, please do not use some of our services (we have already explained to you above the types of sensitive personal information to be collected and processed concerning specific services).

Recipients of Your Personal Information

In addition to the recipients described in section “Recipients of your Personal Data” under the Privacy Policy, Emulate may also share your personal information with our affiliated companies worldwide in order for us to conduct marketing and promotion of the products, services or activities you may be interested in, to help us analyze and know the users’ demand, to improve our products and services, to upgrade user experience, etc., in connection with fulfillment of legitimate business uses that are intended to serve you.

International Transfer

Your personal information collected by us may be transferred to, stored at, processed in or otherwise accessed from a place located outside of the PRC. We will take measures to ensure the security of such transfer, storage and processing of your information in accordance with the Privacy Policy, the PRC Policy and applicable laws, including (i) entering into data processing and data transfer agreements with our affiliated companies, third-party service providers, distribution partners, and others outside of China that incorporate China Cyberspace Administration’s standard contractual clauses or implement other appropriate safeguards with them; (ii) according to the requirements under applicable law, conducting personal data protection impact security assessment or adopting other compliance measures. We will also obtain your separate consent for international transfer of your personal information to the extent required under applicable laws.

How We Protect Your Information

We implement security measures and maintain physical, electronic and managerial procedures in accordance with the Privacy Policy, the PRC Policy and applicable laws in order to safeguard and secure your information processed by us. However, no data transmission over the Internet is completely secure, and we cannot guarantee the security of your information. All the transmission of your information to us should be at your own risk.

Retention Period of Your Personal Information

We have implemented appropriate retention periods for your personal information collected or otherwise processed on or through the Site. Unless otherwise required by applicable law, we will only keep your personal information as long as for the purposes described in the Privacy Policy and the PRC Policy. Personal information processed by us will be retained by us for the term of the contract and for a reasonable time afterwards as might be required to determine and settle any related claims.

Your Personal Information Rights

In addition to the rights set out in Section “Removal and Updating of your Personal Information” in the Privacy Policy, to the extent permitted by applicable laws, you shall have the rights to:

To exercise any of your rights above, please email a request to [insert email for contact on privacy issues]. Emulate will review and carry out valid requests. If the request is not deemed valid or cannot be processed, Emulate will share the reasons why it is not valid or unable to process and your options for seeking resolution through a supervisory authority and through judicial remedy. You have the right to lodge a complaint against us with the competent PRC authority.

Protection of Children’s Personal Information

Protecting children’s personal information is very important to us. We do not accept or will not knowingly collect personal information from anyone under the age of fourteen (14). If you believe that any children’s personal information may have been provided to us, please contact us at [email for privacy inquiries] We will take steps to delete the information as soon as possible should we learn that we have collected the personal information of a child without first receiving verifiable parental consent.

Scope

The statements below describe how Emulate protects and uses data provided by web site visitors and Emulate contacts from the European Union (EU), European Economic Area (EEA), and United Kingdom (UK). Unless outlined specifically below, terms specified in above Privacy & Security Statement will remain valid.

Controller and EU Representative

Emulate, Inc.
27 Drydock Avenue
Boston MA 02110
Our EU Representative is 
Emulate Bio UK LTD
Suite 2 First Floor
10 Temple Back
Bristol
United Kingdom, BS1 6FL

If you have any questions about this Privacy Statement, please contact us at Legal@Emulatebio.com

Data We Use and Legal Basis for Processing Data for the EU, EEA and UK

We process your personal data (first name, last name, phone number, job title, IP address, unique cookie identifiers) on several different legal bases, as follows:

Data Transfers to Recipients Outside of the EU/EEA/UK

We and many of our affiliated companies and third-party service providers are located outside of the EU, EEA or UK.

To ensure an adequate level of protection of your personal data, we enter into data processing and data transfer agreements with our affiliated companies and third-party service providers outside of the EU, EEA or UK that incorporate the provisions of the Standard Contractual Clauses approved by the EU Commission or implement other appropriate safeguards with them. You can ask for a copy of these safeguards by contacting Legal@EmulateBio.com.

Your Rights Regarding the Processing of Your Personal Data

In the EU, EEA or UK you have the rights to:

To exercise any of your rights above, please email a request to [Legal@EmulateBio.com]. Emulate will review and carry out valid requests. If the request is not deemed valid, Emulate will share the reasons why it is not valid and your options for seeking resolution through a supervisory authority and through judicial remedy. You have the right to lodge a complaint against us. To do so, contact the authority in your country of residence.