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PRIVACY POLICY (v. 2/8/2022)

Please read Cellular Technology Limited’s Privacy Policy carefully before accessing or using this Website This Privacy Policy describes the types of information Cellular Technology Limited and its affiliates (“CTL”, “we”, “our” or “us”) may collect from you or that you may provide when you visit the Website located at http://immunospot.com (the “Website”).

CTL respects the privacy of visitors to our Website, and we recognize the importance of taking steps to protect the privacy of information we collect. This Privacy Policy describes the types of Personal Data we collect about visitors to the Website, how we may use the Personal Data, and with whom we may share it. This Privacy Policy also describes the measures we take to safeguard the Personal Data we collect and your rights and privileges concerning our collection, use, and disclosure of your Personal Data.

By accessing or using the Website you accept the practices and policies outlined in this Privacy Policy and you hereby consent that we will collect, use, and disclose your information as set forth in this Privacy Policy. If any term in this Privacy Policy is unacceptable to you, please do not use the Website, or provide any personal information.

Introduction

“Personal Data” is data that can be used to identify or contact you, such as your contact details, including your name, address, e-mail address, country, telephone number, and may also include any data about your use of our Website or your device that may be collected automatically, including through the use of cookies, web beacons and other tracking technologies.

CTL will handle your Personal Data in accordance with applicable law and in line with the following principles:

  • We will process Personal Data lawfully, fairly and in a transparent manner.
  • We will only collect Personal Data for a specified, explicit and legitimate purpose, and we will only use personal information for the purposes for which it was originally collected.
  • We will limit collection of Personal Data to the extent necessary in relation to the purpose for which they are processed.
  • We will make reasonable efforts to ensure that your Personal Data is accurate and, where necessary, kept up to date.
  • We will store Personal Data for no longer than is necessary for the purpose for which the Personal Data are processed.
  • Personal Data will only be processed in a manner that ensures appropriate security of the personal information.• Personal Data will only be processed in a manner that ensures appropriate security of the personal information.

Information We Collect

CTL collects several types of information from and about visitors of our Website including:

Personal Data, generally. CTL may collect Personal Data (as defined above) from visitors of our Website;

Personal Data About Use of the Website and your Interaction with our Emails Collected by Cookies or Other Automated means. When you use our Website or open an email from us, we may automatically collect information about your use of the Website or information about your interaction with our emails (such as when the email has been received and read), including through the use of cookies, web beacons and other tracking technologies (“automated information”). Automated information may include device information such as IP address, device identifiers, and operating system, as well as usage information such as time and duration of use, interaction with content, information stored in cookies or similar technologies. Pursuant to EU Regulation 2016/679 on data protection (the “GDPR”), automated information is considered personal data, and we will treat such automated information as Personal Data in accordance with this privacy policy.

“Cookies” are text files placed on your computer's hard drive to collect standard Internet log information and visitor behavior information. When you visit our Websites, we may collect information from you automatically through cookies or similar technology. Cookies cannot read data off of your hard drive. For further information visit www.allaboutcookies.org.

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

We use the following cookies on our Website:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Website.
  • Functionality cookies. These are used to recognize you when you return to our Website and to embed functionality from third party services. This enables us to personalize our content for you, remember your preferences (for example, your choice of language) and to integrate useful services provided by third party providers into our Website.
  • Analytical and Advertising cookies. We collect certain analytical information to help us better understand activity on our Website and improve our services and the quality of our Website. This information includes the IP address, page requests, referring Websites or ads, operating system and browser, and time spent on our Website. We receive this data in an aggregated form. We use this information to help us understand how visitors engage with our Website, measure the effectiveness of our advertising on third-party Websites, and to improve our visitors’ experience. We sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another Website, you may be shown advertising based on your browsing patterns on our Website.

You may opt-out of cookies from our Website via the Enable/Disable Cookies button in your browser; however, opting out of some of these cookies may have an effect on your browsing experience.

Aggregated Data. We may disclose aggregated, de-identified information about our visitors, and information that does not identify any individual, without restriction. We may disclose your personal information to third parties in connection with the provision of our services or as otherwise permitted or required by law. You agree that we have the right to disclose personal information that we collect or you provide as described in this Privacy Policy, including:

  • Pursuant to your written instructions.
  • To any member of our group, which means our subsidiaries and affiliates.
  • To our third-party service providers that provide services such as the hosting our Website data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing, and other similar services.
  • To comply with any court order, law, legal process, including responding to any government or regulatory request, and to any third parties we believe necessary or appropriate to comply with applicable laws.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CTL’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CTL about our Website users are among the assets transferred.
  • To fulfill the purpose for which you provide it. For example, if you email us asking us to contact a third party (including a medical professional), we may transmit the contents of your email to the recipient.
  • For any other purpose disclosed by us when you provide the information or with your consent.
  • If we are under a duty to disclose or share your personal information to comply with any legal obligation including for billing and collection purposes; or to protect the rights, property, or safety of CTL, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

How We Use Personal Data

We may use Personal Data for the following purposes.

Our legitimate interests

We may process your Personal Data where it is necessary for our legitimate interest as a company, including to manage, promote and improve our business and manage our risk. For example, we may process your Personal Data to:

  • provide you with information you requested and/or to respond to your inquiries submitted via the Website, email and/or phone,
  • facilitate our recruitment activities (such as processing employment applications, evaluating you as a job candidate for an employment activity, and monitoring our recruitment statistics),
  • analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read),
  • tailor the content we display on our Website,
  • protect against, identify, investigate and respond to fraud, illegal activity (such as incidents of hacking or misuse of our Website) and claims and other liabilities,
  • help us comply with our legal or regulatory obligations or our contractual obligations to the U.S. government as a government contractor,
  • maintain the privacy, security, safety or property of the Website, and
  • communicate with you for other purposes which are evident from the circumstances or about which we inform you when we collect Personal Data from you.

Legal Obligation

  • We may be required by law or regulation to collect and process certain Personal Data about you. For example, we may be required to process certain personal data in relation to reporting of adverse events.

Public interest

  • We may also process Personal Data in order to carry out scientific research in the public interest.

Your consent

We may also seek, either directly or through our trusted third parties, your separate consent to process your Personal Data, for example, when you choose to receive CTL news and updates from us, or for the use of non-essential cookies. If we have sought your consent to process your Personal Data, you may subsequently withdraw it at any time by contacting us at the address listed in the “Your Privacy Rights” section below.

Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.

Do Not Track. We do not currently respond to “do not track” signals as we do not track our customers across third party Website. We do not control third parties’ collection or use of your information to serve interest-based advertising.

International Data Transfers

When we share Personal Data with a third party, such data transfers may include the transfer of Personal Data to other countries. Those countries may not have the same data protection laws as the country in which the Personal Data initially originated.

Your Privacy Rights

This Website is hosted on servers located in the United States. We will endeavor to meet those data protection laws and regulations (including the General Data Protection Regulation, or “GDPR”) to which we may be subject as and when applicable to the services provided by us.

The GDPR was passed by the European Parliament and establishes a standard for data privacy for all member states of the European Economic Area (“EEA”) (“EU”). Its purpose is to give EEA residents (described as “data subjects” by the GDPR) certain rights over their Personal Information, including, the:

The right to access - You have the right to request CTL for copies of your personal data. We may charge you a small fee for this service.

The right to rectification - You have the right to request that CTL correct any information you believe is inaccurate. You also have the right to request CTL to complete information you believe is incomplete.

The right to erasure - You have the right to request that CTL erase your personal data, under certain conditions.

The right to restrict processing - You have the right to request that CTL restrict the processing of your personal data, under certain conditions.

The right to object to processing - You have the right to object to CTL's processing of your personal data, under certain conditions.

The right to data portability - You have the right to request that CTL transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: DataProtectionOfficer@immunospot.com.

Or write to us:

Data Protection Officer

Cellular Technology Limited

20521 Chagrin Boulevard

Shaker Heights, OH 44122


You may file a complaint with the relevant supervisory authority if you consider that our processing of your Personal Data infringes applicable law.

Information Security

CTL uses commercially reasonable administrative, technical, personnel-related, and physical security measures designed to safeguard the Personal Data in our possession against loss, theft and unauthorized use, disclosure, or modification. Of course, despite these measures, we cannot guarantee perfect security of the networks, servers, and databases we operate or that are operated on our behalf. In particular, email sent to or from the Website may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to us via the Website.

Data Retention

Your Personal Data will be retained by CTL only for as long as necessary to fulfill the purpose(s) for which it was collected, depending on the purpose(s) for which the Personal Data was collected, the nature of the Personal Data, any contractual relationship that governs the retention of the Personal Data, and our legal or regulatory obligations. We will then destroy or anonymize your Personal Data, in accordance with applicable law.

Email Communications

In the event that we contact you, including via email, we will provide you with a method to opt out of or opt in to receiving further communications to the extent required by law. If at any time, that you no longer wish to receive email communications from us, you may unsubscribe to any contact list by using the relevant “Unsubscribe” link within the respective electronic communications channel or by emailing us the request at DataProtectionOfficer@immunospot.com.

Minor’s Protection Policy

We do not knowingly collect information for individuals under the age of 18 for whom we have not obtained adequate consent as set forth below. If you are under 18 years of age, we must obtain valid and verifiable consent by your parent or legal guardian to this Privacy Policy before you can use Website and services. Such consent will be obtained via reasonable methods, as determined by us in our sole discretion. If we determine that the consent obtained is inadequate, we will notify you and you may not use or access the Website or services at any time or in any manner. However, if you are a parent, legal guardian or personal representative of a minor child under 18 years of age, you may use our services on behalf of such minor child. Any information you provide us on behalf of your minor child will be treated in accordance with this Privacy Policy. If we learn that we have received any information for an individual under the age of 18 for whom we have not obtained adequate consent pursuant to the above, we will only use that information to respond directly to that child (or a parent, legal guardian or personal representative) to inform him or her that he or she cannot use our services, and subsequently we will delete that information from our own servers. If you believe we might have any information from or about a child under 18, please contact our Data Protection Officer using on of the methods provided below.

Offline Information and Links to Third Party Websites

This policy only addresses Personal Data collected through this Website. It does not describe the ways in which we may collect or use Personal Data obtained offline in other ways, and it does not address or control the privacy practices of other Websites (including those we link to), which may have their own policies. If you click on a link to another Website, you should read their privacy policy. CTL is not responsible for, the privacy, information, or other practices, including data privacy and security process and standards of any third parties.

Changes to our Privacy Policy

CTL reserves the right to change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy posted on this page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically monitoring and reviewing any updates to the Privacy Policy. Your continued use of our Website after such amendments will be deemed your acknowledgment of these changes to this Privacy Policy.

How to contact us

If you have any questions about CTL’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please contact our Data Protection Officer at DataProtectionOfficer@immunospot.com or write to us at:

Data Protection Officer

Cellular Technology Limited

20521 Chagrin Boulevard

Shaker Heights, OH 44122