Oxitec’s Flyttr Privacy Policy

Important Information and Who We Are

This Privacy Policy gives you information about how Oxitec collects and uses your personal data when you interact with us through your interaction with and use of Flyttr, including when you:

• visit our Flyttr website (www.ai.flyttr.com) (Website)
• use our Flyttr Dengue websites, apps, or other online services hosted at www.ai.flyttr.com/dengue/platform (Platform);
• subscribe to receive newsletters and other information from us;
• request information from us or provide information to us; and
• contact us by any means.

The Website and the Platform are not intended for children and we do not knowingly collect data relating to children.

Controller

This Privacy Policy is issued for Flyttr’s Website and Platform on behalf of Oxitec Ltd and Oxitec do Brasil Tecnologia de Insetos Ltda so when we mention Oxitec, we, our, or us in this Privacy Policy, we are referring to the relevant company responsible for the processing your data.

Oxitec Ltd is the controller for Flyttr’s global operations, the Website and the Platform. Oxitec do Brasil acts as a joint controller and/or data processor for any data subjects based in Brazil.

What Data We Collect

Personal data means any information about an individual from which that person can be identified. We do not collect any special category personal data (also known as sensitive personal data).

We may collect, use, store and transfer different kinds of personal data about you with we have grouped together as follows:

• Identity Data: includes name, surname, title / job title or professional affiliation, age, gender, username or similar identifier, as well as organisation details
• Contact Data: includes email, telephone, address, postal code.
• Transaction Data: payment or billing details.
• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and geolocation, browser plug-in types and versions, operating system and platform, device type, device ID and other technology on the devices you use to access the Website or Platform.
• Profile Data: includes your username and password, your interests, preferences, feedback and survey responses.
• Usage Data: includes information about how you interact with and use the Website or Platform.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.

We (and service providers that we use) also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with the Website or the Platform to help improve the Website, the Platform and our service offering, but also for other business purposes.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms, by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you interact with us as set out above.
• Automated technologies or interactions. As you interact with the Website or Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further information.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources including as set out below:
  • Identity and Contact Data from the organisation you represent.
  • Technical Data is collected from the following parties:
    • analytics providers;
    • advertising networks; and
    • search information providers.
  • Contact and Transaction Data is collected from providers of technical services.
  • Identity and Contact Data is collected from publicly available sources such as Companies House in the UK and social media platforms.

How We Use Your Personal Data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract. Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure experience when using the Platform or the Website. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis
To manage our relationship with you or with your organisation as a customer, including: (a) when you contact us to find out more about our Flyttr solutions; (b) to register your organisation as a new customer for the Platform; and (c) to provide support services in respect of any of the Platform;	(a) Identity (b) Contact (c) Transaction	(a) Necessary for our legitimate interests (to perform our obligations under a contract with your organisation) (b) Performance of our contract with you (if you are our customer)
To register you as a user of the Platform and allow you to use the Platform	(a) Identity (b) Contact (c) Profile (d) Usage (e) Technical	(a) Necessary for our legitimate interests (to perform our obligations under a contract with your organisation) (b) Performance of our contract with you (if you are our customer)
To process and deliver our Flyttr solutions to your organization or you, including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications	(a) Necessary for our legitimate interests (to perform our obligations under a contract with your organisation and to recover debts due to us) (b) Performance of our contract with you (if you are our customer)
To manage our relationship with you which will include: (a) notifying you about changes to our terms or Privacy Policy (b) dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Necessary to comply with a legal obligation (b) Performance of our contract with you (if you are our customer) (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)
To enable you to complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (to study how customers use our Flyttr solution, to develop them and grow our business)
To administer and protect the Oxitec business, the Website and Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use the Website / Platform, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve the Website, the Platform, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Website / Platform updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about our solutions that may be of interest to you based on your Profile Data	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(a) Consent, having obtained your prior consent to receiving direct marketing communications (b) Necessary for our legitimate interests (to carry out direct marketing, develop our solutions and services and grow our business)

Direct marketing

During the registration process on the Platform, you may be asked to indicate your preferences for receiving direct marketing communications from us. You may also receive direct marketing communications from us if you have signed up to the Flyttr newsletter on the Website.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which one of our solutions or services may be of interest to you so that we can then send you relevant marketing communications (we are either sending you direct marketing communications because you have asked us to send you such communications or we are otherwise legally allowed to send you such communications).

Third-party marketing

We will not share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out (unsubscribe) links within any marketing communication sent to you or by contacting us at info@flyttr.com.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates to the terms on which you are permitted to use the Platform.

Sharing Your Data

We will share your personal data with other Oxitec entities. We may also share your personal data with the following third parties in accordance with this Privacy Policy, including:

• Vendors and service providers who support our operations, such as by providing IT and system administration services, hosting services for the Platform or the Website, customer service support, email delivery and administration, and data storage and analysis.
• Our professional advisors, including lawyers, auditors, insurers and consultants who provide legal, accounting, insurance and other services.
• The organisation that you represent, who is our customer.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets (or with whom we may discuss any such activities) or who may (or contemplate) invest in us or any part of us. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
• Shareholders and investors who we provide with information as part of our reporting activities.
• HM Revenue and Customs, regulators, law enforcement, public authorities or other third parties where necessary to exercise our rights or comply with a legal obligation.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We do not sell, rent or trade personal data.

International Data Transfers

Whenever we transfer your personal data out of the UK or EEA (for example, to Brazil or any other country in which Oxitec operates), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government or the European Commission, as applicable.
• We use specific contracts approved for use in the UK by the UK government or the EEA by the European Commission, in each case which give the transferred personal data the same protection as it has in the UK and/or, as applicable.

Please contact us using the contact details above if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy.

Data Security

Oxitec has put in place appropriate physical, technical, and organizational data security measures designed to safeguard and protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

However, due to the risks inherent in the digital environment, Oxitec provides no guarantees that your personal data will not be unlawfully accessed by unauthorized third parties.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Rights

You have a number of rights under data protection laws in relation to your personal data.

UK / EU data protection laws

The below mentioned rights only apply if Oxitec is established in the UK / EEA or you are a resident in the UK / EEA. You have the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us. If we intend to rely on legally permitted reasons not to comply with your request, we will explain this to you.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Brazilian data protection laws

Under Brazil’s LGPD, you may confirm processing, access, correct, delete, anonymise, or transfer your data, and withdraw consent. Contact juridico@oxitec.com to exercise your rights.

Complaints

UK / EEA data protection laws

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). If you are based in the EEA, you also have a right to complain to your national data protection regulator. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or your national data protection regulator so please contact us in the first instance.

Brazil

If you wish to make a complaint in Brazil, please contact the Autoridade Nacional de Proteção de Dados (ANPD) — www.gov.br/anpd

Links to Other Websites

The Website and the Platform may include links to third-party sites and content not related to Oxitec. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not (to the extent legally permitted) responsible for their privacy statements. When you leave the Website or the Platform, we encourage you to read the privacy policy of every website you visit.

Changes to this Privacy Policy and your Duty to Inform Us of Changes

The date of the latest update to the Privacy Policy will be shown at the top of this policy, and we’ll inform you of any changes. Still, we suggest checking back periodically. Updates become effective right after they’re posted, and apply to all future access and use of the Website and Platform.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

Contact Us

If you have any questions, requests or comments about this Privacy Policy or the use of your personal data, or if you wish to exercise any of your rights described above, please contact Oxitec at: