Prolucent Health, Inc.
Privacy Policy

Last Updated: April 20, 2023

Your privacy is very important to us. Prolucent Health, Inc. and its affiliates (“we”, “us”, or “our”), respect your privacy and are committed to protecting it through our compliance with this policy. This Policy describes how we collect, use, store, process, protect and disclose “Personal Information,” which is generally information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device, as more fully described below, which we obtain from you when you visit the websites that we own or control (today or in the future), including www.prolucent.com, www.liquidcompass.com (the “Sites”), you use the mobile applications we own or control (today or in the future) including the Liquid Compass App (the “Apps”), and when you use any services we provide through the Sites or the Apps (collectively, with the Sites and the Apps, the “Services”). You can access the Services in many ways, including from a computer or mobile phone, and this Policy will apply regardless of the means of access.

This Policy also governs the use of Personal Information we obtain from you from any third-party site or application that you authorize to provide us with Personal Information. This Policy also sets forth your rights and choices regarding the how we collect, use, and share your Personal Information.

In cases where you follow a link to a third-party website, you are no longer covered by our Privacy Policy, and any data collection or processing activity that takes place on that website will be governed by that website’s own privacy policy. We only collect data on the Sites that display a direct link to this Privacy Policy. Please be aware that we cannot control the privacy policies or practices of sites or companies that we do not own or control and cannot control the actions of people we do not employ or manage.

Please read this Policy carefully. This Policy is incorporated into and is subject to our Terms of Service for the applicable Services, which are available at https://www.liquidcompass.com/terms-of-use. In the event of a conflict between this Policy and such Terms of Service, the applicable Terms of Service will control. We have tried to make this Privacy Policy clear and easy to navigate, but if you have any questions about this Policy, please e-mail us at privacy@prolucent.com. If you do not want us to collect, use, store or share your Personal Information in the ways described in this Policy, please do not use the Services. By using the Services, you consent to our collection, use, storage and sharing of your Personal Information as identified in this Policy.

I. Information We Collect
Information You Provide to Us

We collect information that you provide to us. When you use some of our Services, you may choose to provide certain information directly to us, to request more information, or for other reasons. We will collect, use, store and/or share such information, which may include Personal Information, consistent with this Policy. Examples of the Personal Information we collect that you provide to us include
information you provide when you:

fill in forms or create an account or user profile on one of our Sites or Apps or otherwise use the Services
request customer service, ask service-related questions, share suggestions or feedback, or
otherwise correspond with us using the Services, email, phone, or access or interact with our pages or accounts on third-party social media platforms such as Facebook, Twitter, Instagram, or
LinkedIn
use the Services
submit a resume or apply for job
submit reviews or comments on our Services or social media pages
participate in a promotion, survey, sweepstakes, or contest
submit a resume or apply for a position

The types of Personal Information you may share with us include your name, email address, physical or postal address, phone number (including your mobile phone number), and the username and password
you select to use the Services. We will also collect and maintain information about all transactions associated with your accounts.

Information We Receive From Third Parties

We may collect your Personal Information from third party affiliates or business partners such as social media sites, ad networks, analytics providers, our distributors, dealers, and retailers, and advertising and marketing agencies and vendors. We may also receive information from other sources to help us supplement our records, improve the personalization of our service to you, and detect fraud. Our goal is to limit the information we collect to the information needed to support our business.

Information We Collect Through Automatic Data Collection Technologies

You also provide us information in other ways through technology to help our Sites and Apps work properly and support customer service, marketing, and analytics efforts to help us understand our customers’ needs and provide information about our products and services. Some of this information may be linked to you personally. When you use our Services, our servers automatically record information that your browser or device sends whenever you visit a website or utilize an application. This information may include your IP address, the type of device you are using, the internet service provider or mobile carrier you are using, your device identifiers, your mobile telephone number, your geographic location and your activities within the Services, including the links you click, the pages or screens you view, your session time, the number of times you click a page/screen or use a feature of the Services, the date and time you click on a page or use a feature and the amount of time you spend on a page or using a feature.

Our Sites also use “cookie” technology to collect additional website usage data and to improve the Sites and our Services. A cookie is a small data file that we transfer to your computer’s hard disk. A session cookie enables certain features of the Sites and is deleted from your computer when you disconnect from or leave the Sites. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Sites. We may use both session and persistent cookies to better understand how you interact with our Sites, to monitor aggregate usage by our uses and web traffic routing on our Sites, and to improve our Sites and Services. You may also be able to configure your computer or mobile device to limit the collection of these “cookies,” but that limitation may also limit our ability to provide all of the services or functionalities of the Sites.

We may also automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or after you visit our Sites, the pages or other content you view or otherwise interact with on our Sites and the dates and times that you visit, access or use our Sites. We may also use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on or forwarded a message, to the extent permitted under applicable law.

We also use Google Analytics to collect information automatically. Google Analytics only collects the IP address assigned to you on the date you visited the site and does not gather your name or other identifying information. We do not combine the information collected through Google Analytics with your identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the site, the cookie cannot be used by anyone but Google. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. For information about how to opt-out of Google Analytics Advertising Features, visit:

https://tools.google.com/dlpage/gaoptout/

When you use our Services anonymously, we may use Segment to create a unique identifier for you using your IP address that records your activities on our Sites but does not otherwise identify you. If you later choose to create an account on the Services, your historical visit information is merged into your user account to improve your user experience and allow us to recommend job listings based on your interests.

In short, we use these automated technologies to collect the following information:

your IP address, browser type, and operating system;
the mobile device you use and its temporary or persistent unique device identifiers;
pages you view within the Services;
websites you visited before coming to the Services;
video viewing history for videos you watch on the Services;
emails from us that you open and/or forward;
offers or links from us to which you connect; and
information about products you purchase using the Services, including payment method, the date and time of the transaction, items purchased, the purchase price, and other order or purchase related information.

Information Collected by Third Parties

We may display third-party content on the Sites and the Apps, including third-party advertising. Thirdparty content may use cookies, web beacons or other mechanisms for obtaining data in connection with your interaction with such third-party content. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by us. Please consult such third party’s data collection, use and disclosure policies for more information. If you do not consent to such third-party data collection, use and disclosure practices, do not use or interact with the third-party content on the Sites and Apps.

Links to Other Websites

The Sites and Apps may contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer or mobile device, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We are not responsible for the content, privacy and security practices, and policies of third party sites or services to which links or access are provided through our Sites and Apps. We encourage you to read the privacy policies or statements of the other websites you visit.

II. How We Use The Information We Collect Non-Marketing Purposes

We may use the information we collect for non-marketing purposes including:

validating your identity and managing your account with us;
processing your transactions and providing our products and services to you;
communicating with you for non-marketing purposes, including order processing and fulfillment and about employment opportunities and job openings;
sending you push notifications or e-mails to provide you with alerts and updates about your account and our Services;
conducting statistical or demographic analysis;
complying with legal and regulatory requirements;
customizing and improving your experience with the Services or our products;
protecting and defending Prolucent and its affiliates against legal actions or claims;
detecting and preventing fraud;
debt collection;
satisfying contractual obligations;
cooperating with law enforcement or other government agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Information is necessary or appropriate to protect the public interest;
improving customer service;
providing you the features and functionalities associated with the Services;
evaluating and considering your application for a job with us or our customers that use the Serviecs to to post job listings;
any other purposes for which we obtain your consent; and
for other business purposes permitted under applicable law (collectively, “Non-Marketing Purposes”).

Marketing Purposes

With your advance consent, we may use the Personal Information we collect for our own marketing purposes including notifying you of special promotions, offers and events via push notifications, email and other means, including text/SMS messaging, subject to compliance with applicable laws. We may also link Personal Information (including your name, mobile phone number, and email address) with non-personal information (including information automatically collected as described in this Policy) and use such information for our own marketing purposes.

Other Purposes

We may also use information in the aggregate to understand how our users as a group use the Services provided on our Sites and Apps. We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated or incompatible purposes without providing you notice.

III. How and With Whom We Share Your Information

For business purposes, we may share certain Personal Information we receive from and about you, and about your transactions with us, with our affiliates and certain third parties, including our contractors, service providers and other third parties we use to support our business. Doing so allows us to provide the Services you request.

We may also share your Personal Information with the following third parties:

Employers and Potential Employers

Your Personal Information may be shared with our customers who use the Services to post job listings using the Services or our customers who contract with us and use our vendor management platform to assist with the processing of time and attendance data for their employees and contractors. Your Personal Information may be shared with our customers’ employee management platforms as needed to process payroll and benefits.

Third Party Service Providers

Your Personal Information may be shared with or collected by third party service providers who provide us with services, including, but not limited to, facilitating mailing information and services, data hosting or processing, and processing and fulfilling transaction. We require these third-party service providers to exercise reasonable care to protect your Personal Information and restrict their use of your Personal Information to the purposes for which it was provided to them.

We may also allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. For example, we use Google Analytics, as explained above.

Anonymous Information/Aggregated Information

We may freely use aggregated and anonymized information as allowed by law and share it with third parties. Any anonymized information we provide to third parties does not identify you and is not considered Personal Information, and, as such, is not subject to the terms of this Policy.

Sale of our Business; Bankruptcy

In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, we may transfer or allow third parties to use information owned or controlled by us. We reserve the right, in connection with these types of transactions, to transfer or assign your information and other information we have collected to third parties or to authorize third parties to use any such information retained by us. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new Privacy Policy adopted by the successor entity.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against legal claims, for legal process (including subpoenas), to protect our property and rights or those of a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Services and any equipment used to make the Services available, or to comply with applicable law.

IV. Access to Information and Your Choices

We provide you with the opportunity to access, update or delete certain information and to unsubscribe or opt-out from certain communications. For example, you may exercise your choices as explained below.

Please be aware that, if you do not allow us to collect and use your personal information, we may not be able to deliver certain products, services, promotions, and offerings to you. To protect your privacy and security, we reserve the right to take reasonable steps to verify your identity before granting you account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.

Account Management Options

You may access, correct or update certain personal information you have provided to us at any time by accessing your user account. You may also choose to close your user account by accessing your profile online. You may also choose how and whether to receive promotional or marketing communications from us by exercising your choices by following instructions available on the Services or in communications sent to you.

Opt-Out/Correction/Deletion Requests

With your advance consent, you may receive mailings or emails from us with news or other information on events, products, services, discounts, special promotions, upcoming events or other offers from us or on our behalf. If at any time you wish to stop receiving emails, mailings, or other communications from us please reply to any of our emails and type “unsubscribe” in the subject line or send us an email to privacy@prolucent.com and we will remove you from our mailing list. Please note that we may continue to send transactional or account-related messages to you.

Alternatively, for email communications and text/SMS messages, you may opt out of receiving such communications by following the unsubscribe instructions set forth in the messages you receive from us. Your unsubscribe request or email preferences change will be processed promptly, though this process may take several days. During that processing period, you may receive additional email or text/SMS communications from us.

We will support your ability to access, correct, and delete your Personal Information. If we have obtained your Personal Information from a other third party, we may confirm your request through them. For assistance with exercising your choices, or if you have any questions about your choices, please contact us at privacy@prolucent.com.

V. Security

We are committed to protecting the security of the Personal Information you provide to us and that we collect about you. We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Information that you provide to us. Our safeguards vary based on the sensitivity of the information that we collect and store.

Nevertheless, when disclosing Personal Information, you should remain mindful that there is an inherent risk in the use of email and the internet. Your information may be intercepted without our consent, collected illegally and used by others without your consent. We cannot guarantee the security of any information you disclose online, and you do so at your own risk. You are responsible for maintaining the security of your account username and password. We recommend that you change your password periodically. If you believe that your account username and/or password have been stolen or been made known to others, it is your responsibility to immediately contact us at privacy@prolucent.com and change your password. We are not responsible if someone else accesses your account through information they have obtained from you.

VI. Underage Persons

The Services are for use by persons who are at least 13 years of age. If you are younger than 13, you may not access, attempt to access, or use the Services. We do not knowingly collect or allow the collection of Personal Information via the Services from persons under the age of 13. If we learn that we have collected the Personal Information of someone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information, you may contact us at privacy@prolucent.com and ask us to remove your child’s Personal Information from our systems.

VII. Collection and Use of Personal Information of Employment Applicants
For Prolucent Opportunities

If you complete an application for employment with us or request information regarding such opportunities, we may collect personal information that you provide (such as information contained in a resume or cover letter) in connection with your request for information and/or to evaluate your application for employment. We may also collect personal information about you from third parties to supplement, update, or verify your information, and/or to process your application. Applicable law may require that you authorize a third party to share your personal information with us before we can acquire it. Failure to provide any requested information may negatively impact consideration of your employment application. By applying to become an employee of Prolucent or its affiliates, you consent to our collection, use, and disclosure of your personal information as described above, to the extent permitted by applicable law.

For Users Applying for Third-Party Opportunities Using the Services

Resume data

By creating a searchable resume through the Services, uploading a file resume on the Services, or providing information in other application materials, you are requesting and authorizing us to make available your resume and such information to third parties, in accordance with our Terms of Service. You voluntarily choose what data is included on your resume and other application materials. When you create a profile, your resume is set to searchable by default. This means that profile data and resume data (searchable) may be available to third parties, such as potential employers. Data contained in your resume and application materials is referred to as “Resume Data.” Data contained in your user profile is referred to as “Profile Data.”

Please note employers who access your Resume Data while it is set to searchable visibility, or to whom you apply with your not searchable resume, may choose to share your resume with additional parties. We are not responsible for such sharing. Similarly, when you share your searchable resume directly with a personalized link, we cannot control who sees your resume when you share that link.

Automated Processing of Your Personal Data

We perform automated processing of Personal Information to evaluate specific aspects relating to a user and to analyze and predict a user’s preferences and interests. Where we perform this processing, we do so either on the basis of user consent or performance of a contract, whereby such processing is necessary for us to provide our services to job seekers and employers. For example, such processing allows us to match job seekers with employers effectively, to provide job seekers with recommended jobs, and invitations to take action on jobs that you may be interested in, to send particular job seeker applications to an employer, to display search results, to send application status notifications on behalf of employers, or to perform certain spam and fraud detection activities to protect our users. Such processing is subject to the safeguards detailed in this Privacy Policy to protect the privacy of our users. You may contact privacy@prolucent.com to exercise your rights or contest any decision generated by said automated processing.

Transfers of Information to Employers

We send job seeker Personal Information, Resume Data, and Profile Data to employers, including, on the instruction of job seekers and employers. Such transfers are performed in the course of the job search, application, and interview process. Information transferred to employers in this way is processed in accordance with our Terms of Service and those of the employer. This transfer may include sending your application and/or additional candidate information, such as your contact details, to other platforms that process information for the employer, such as the employer’s applicant tracking system or scheduling platform.

Employers agree to comply with all their responsibilities under applicable data protection rules with respect to the collection, processing, and storage of Personal Information, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules.

Transfers of Information to Job Seekers

We may send certain employer-related information to you, such as job ads, company pages, and other information relating to potential employers and employment opportunities. This information may also include the employer representative’s name, the employer’s city/state location, whether the employer has taken or has chosen not to take an action with regard to the job seeker’s resume or application such as opening, viewing, responding to or making a decision in regard to it, and whether the employer has taken an action in regard to a job listing. As an employer, when you use the Services ) you agree that we may provide this information to job seekers.

VIII. Retention

We retain personal information for as long as necessary to fulfill the purposes for which it is collected or processed. We also retain information for related business purposes, security, legal compliance, and disputes and claims handling as permitted by applicable law.

IX. International Users

The Sites and Apps are only intended for residents of the United States. If you are not a resident of the United States, please do not provide us with any Personal Information.

X. Changes to this Policy

We may revise this Policy from time to time in our sole discretion, and the updated Privacy Policy applies to you after the effective date of the revision. Your continued access or use of the Services following any amendments to the Policy constitutes your acceptance of the Policy as amended. It is your sole responsibility to monitor our website for changes to the Policy.

XI. Contact Us

If you would like to review, update or correct your information or modify your communication preferences, or if you have questions regarding our Privacy Policy or the use of information collected, you can contact us at: privacy@prolucent.com.

XII. California and Nevada State Law Privacy Rights

If you are a California resident, this Section is provided pursuant to the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100 et seq. and its implementing regulations (the “CCPA”), as modified by the California Privacy Rights Act (the “CPRA”). Please read it carefully. This Section applies to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“California Personal Information”). For California residents to whom this Section applies, the provisions of this Section prevail over any conflicting provisions in other sections of this Privacy Policy.

We have collected the following categories of California Personal Information within the last 12 months from the sources listed below:

Identifiers, such as:
- First name, last name, job applicant account username and password, social security number, drivers’ license or other state identification number, and other similar identifying information.
- Physical address(es), email address(es), telephone number(s), and emergency contact.
- Where applicable and in accordance with applicable law, your ethnicity, disability, military status, or criminal history.
- Schools attended, degrees or certifications earned, grades, disciplinary records, or other education records and information.
- Your current and former employers, job title(s), and position(s).
- Application information including what position you applied for, when you applied, and how you applied.
- Unique personal identifier, and online identifier.
- Internet Protocol address, account name, or other similar identifiers.
- This category of information is collected from you, your devices, third parties (such as linked sites), and public databases.
Personal information described in Section 1798.80(e) (California customer records statute), such as a name, address, and telephone number. This category of information is collected from you, your devices, our affiliates, or other third parties such as our business partners.
Characteristics of protected classifications under California or federal law such as age, gender, race, ethnicity or national origin. While we do not request such information, we may collected it from you if you voluntarily choose to provide it to us in resumes, cover letters, and other application materials you submit using the Services.
Internet or other similar network activity, including, but not limited to, browsing history, search history, browser settings like language preference, and information regarding your interaction with a website, application, or advertisement. This category of information is collected from you and your devices.
Geolocation data, including physical location or movements. This category of information is collected from you and your devices.
Sensory data, including electronic, visual, or similar information. This category of information, such as photos, is collected from you and third parties (such as linked sites), or our service providers.
Resume Data and Profile Data.
Inferences, such as a profile about a consumer’s preferences, characteristics, and behavior, drawn from information we collect and insights we receive from third parties such as our marketing and advertising partners and data analytics providers.

Please see the “Information We Collect” and other sections of this Policy to learn more about how we collect these types of information we collect.

For each of the above categories, we use the California Personal Information for a variety of business purposes such as:

Fulfilling your requests for services and information;
Evaluate your application and resume and consider you for current and potential employment opportunities with us or our customers;
Schedule interviews and communicate with candidates about their applications;
Comply with applicable laws, regulations, and legal process;
Maintain records of our interactions and communications;
Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
Debugging to identify and repair errors in our systems;
Short-term, transient use including contextual customization of ads;
Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
Conducting internal research to develop and demonstrate technology;
Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide;
Other business purposes described in the “How We Use The Information We Collect” Section of this Policy;
As permitted by law;
To protect our rights, privacy, safety or property, or that of our employees or other parties; and
For any other purposes with the consent of the California applicants

We may also use the information we collect for our own operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.

Within the last 12 months, we have disclosed California Personal Information for our business purposes, including with our customers who use the Services to post job listings. To learn more about the categories of third parties with whom we share such information, please see the “How and With Whom We Share Your Information” Section of this Policy.

We do not sell and, within the last 12 months, we have not sold, California Personal Information, including California Personal Information of individuals under 16 years of age.

Your California Privacy Rights

If you are a California resident, you have certain rights related to your California Personal Information, including:

The right to request that we disclose to you:
- the specific pieces of California Personal Information we have collected;
- our business or commercial purpose for collecting or selling California Personal Information; and
- the categories of third parties with whom we share California Personal Information.
The right to request that we delete California Personal Information about you.

You may request to exercise these rights by:

Calling us toll-free at 833-222-3001; or
Emailing us at privacy@prolucent.com; or
Writing us at:
- Prolucent Privacy
- Two Lincoln Centre, Suite 550
- 5420 LBJ Freeway
- Dallas, Texas 75240

As required under applicable law, please note that we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide your first name, last name, and email address to verify your identity in response to exercising requests of the above type. You will, therefore, need access to your email account to receive our communications necessary to process your request. Please make sure to check your spam inbox to ensure these important communications are not missed. We may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights above, we will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.

Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. As permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent.

Non-Discrimination

We may not discriminate against you because of your exercise of any of the above rights or any other rights, subject to the rights and the obligations under the California Consumer Privacy Act, including by:

Denying you goods or services;
Charging different prices or rates for goods or services, including through the use of discounts, loyalty programs, or other benefits or imposing penalties;
Providing you a different level or quality of goods or services; or
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

We will not discriminate against you for exercising your CCPA privacy rights.

California Job Applicants

In the context of job applications, we also collect information from you and third parties, including business contact information such as company name, physical address email address, education information, and past work experience and the other types of information described in this Privacy Policy or other notices we provide. If you complete an application for employment with us or request information regarding such opportunities, California Personal Information you provide to us (such as information contained in a resume or cover letter) in connection with your request for information and/or to evaluate your application for employment will be processed in accordance with our Privacy Policy and applicable law.

Do Not Track

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed.

Nevada Residents

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@prolucent.com. However, please know we do not sell data triggering that statute’s opt-out requirements.

XIII. For EU Residents:

The General Data Protection Regulation (“GDPR”), particularly Articles 15 to 21, affords you a number of rights as a data subject. We encourage you to read and learn about those rights on your own. However, the following will help you to begin to understand those rights.

The Right to Access: This allows you to request from us information about your Personal Information, including what data we have and how and why it is being processed.
The Right to Rectification: In the event that some or all of the Personal Information that we have concerning you is inaccurate, this gives you the right to have those inaccuracies rectified.
The Right to Erasure: In some cases, you may have the right to request that we erase your Personal Information that we have in our possession.
The Right to Restriction of Processing: This gives you the right, in some circumstances, to have us process your Personal Information only with your consent.
The Right to Object to Processing: Where we are processing your Personal Information on the ground of its legitimate interests, or to carry out tasks in the public interest or to exercise official authority, you have a right to object to the processing on grounds relating to your particular situation. In cases where you object to our processing of your personal data for direct marketing purposes, the processing will cease.
The Right to Data Portability: This allows you to request from us a copy of your Personal Information that it has on file and to transfer that information to someone else without any interference from us. In some cases, you may be able to request that we transfer your Personal Information directly to a third party on your behalf.

In addition, to the extent that we process any of your Personal Information on the basis of your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing that was based on your consent before its withdrawal.

If you are a natural person residing in the EU and at any time you believe we have violated one of your rights listed above, or if you believe we are in violation of one or more of the provisions of the GDPR, you have the right to lodge a complaint with a Data Protection Authority. More information about the Data Protection Authorities can be found at https://ec.europa.eu/info/law/law-topic/dataprotection/ reform/what-are-data-protection-authorities-dpas_en.

Information and Data Security

We have implemented an information and data security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information.

Transfer of Information, Transfers to Other Countries

We are headquartered in the United States of America. Personal Information may be accessed by or transferred to the United States or to our controlled affiliates and data processors elsewhere in the world for the purposes described in this Privacy Policy. When we access or transfer Personal Information, we do so in compliance with applicable law. Additionally, we protect the privacy and security of Personal Information in the manner described in this Privacy Policy, regardless of where it is processed or stored.

Personal Information that we receive in the United States concerning persons in the European Union is transferred subject to appropriate safeguards, including the European Union’s standard contractual clauses for the transfer of personal data to third countries. A copy of these clauses is available upon request, free of charge. To request a copy of the standard contractual clauses, please contact us using the information provided in this Privacy Policy.

Prolucent Health, Inc. Privacy Policy

Prolucent Health, Inc.
Privacy Policy