Effective as of January 21, 2020.
Prolacta Bioscience, Inc. is a life sciences company that develops specialty formulations made from human milk for the nutritional needs of premature infants in nenonatal intensive care units (NICU).
Prolacta may provide additional privacy notices to individuals at the time we collect their data. For example, we provide a specific privacy notice to clinical trial participants that describes our privacy practices in connection with conducting clinical trials. This type of an “in-time” notice will govern how we may process the information you provide at that time. For example, our privacy practices in connection with clinical trials are governed by applicable clinical trial protocol(s).
Individuals located in Europe should be sure to read the important information provided here.
We collect personal information about the following types of individuals: clinical trial participants, patients, patient family members, donors, caregivers or advocates, physicians and other health care professionals, clinical trial investigators, researchers, pharmacists, users of our Sites, and other individuals who interact directly with Prolacta or our service providers or business partners.
We collect personal information:
The types of personal information we collect and share depend on the nature of the relationship you have with us and the requirements of applicable laws. We may collect:
We may combine other publicly available information, such as information related to the organization for which you work, with the personal information that you provide through the Services.
Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We do not currently respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
If you use our Sites, we use your personal information to:
We may use your personal information when necessary to facilitate our clinical trials, research, studies, and related activities that support product improvement, including to:
We use your personal information as necessary to provide Prolacta Services, including to:
We may send you surveys, promotions or other marketing communications, but you may opt out of receiving them as described in the Opt out of marketing section below.
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
We use your personal information as we believe necessary or appropriate to comply with regulatory monitoring and reporting obligations, such as those related to adverse events, product complaints, patient safety, and financial disclosures.
In some cases we may ask for your consent to collect, use or share your personal information, such as when required by law or our agreements with third parties.
We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our websites, products, and services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
We may employ third-party companies and individuals to perform services on our behalf, including:
We may disclose your personal information to partners with whom we jointly develop products or services, in connection with the development and promotion of such products or services. We will ask for your consent before disclosing your information with our business partners where required by applicable law.
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
We may disclose your personal information to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our websites, products, and services; (d) protect our rights, privacy, safety, or property, as well as that of you or others; and (e) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
In some situations, Prolacta may have a separate agreement or relationship with you with respect to a specific type of processing of your data, such as if you participate in a special program (including donor milk programs), activity, event, or clinical trial. These situations will be governed by specific terms, privacy notices, or consent forms that provide additional information about how we will use your information. We will honor these additional terms with respect to your information and thus, strongly recommend you review the additional terms prior to participating in any programs.
To request access to the personal information we maintain about you, or if you become aware that the personal information we maintain about you is inaccurate, incomplete, misleading or out of date, you may contact us at email@example.com
You may opt out of marketing-related emails by clicking the “Unsubscribe” link at the bottom of each such email or by completing the following Opt-Out form. You may continue to receive service-related and other non-marketing emails.
If you gave us consent to post a testimonial on our websites, but wish to update or delete it, please contact us at firstname.lastname@example.org.
Where we are required by law to collect your personal information, or where we need your personal information in order to provide you with our Services, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Services and may need to terminate our relationship with you. We will tell you what information you must provide to us by designating it as required when we request the information or through other appropriate means.
The security of your personal information important to us. We take a number of organizational, technical, and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are completely secure and we cannot guarantee the security of your information.
We do not knowingly collect personal information from children under age 13 in the United States through our Sites. If we learn that we have collected personal information directly from a child under the age of 13 through our Sites, we will delete that information as soon as practicable.
Prolacta is headquartered in the United States and has affiliates and service providers in other countries. Your personal information may be transferred to the United States or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
Individuals in Europe should read the important information provided here about transfer of personal information outside of the European Economic Area.
For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by Prolacta. These links are not an endorsement, authorization, or representation that we are affiliated with that third party. We do not exercise control over third-party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
Prolacta Bioscience, Inc.
1800 Highland Avenue
Duarte, CA 91010
The legal bases for our processing of your personal information are described in the table below.
|Processing purpose||Legal basis|
|To provide our products and services||
Where we have a contract governing this processing purpose, the processing is necessary to perform that contract or to take steps that you have requested prior to entering into the contract.
In other cases, these processing activities are necessary to protect your, or another person’s, vital interests.
|To perform and administer clinical trials, research, and product-improvement activities||
Where we have a contract governing this processing purpose, the processing is necessary is perform that contract or to take steps that you have requested prior to entering into the contract.
Where we process sensitive personal data in connection with this processing purpose, the processing is necessary for scientific research, historical research, or statistical purposes.
In all other cases, these processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information 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).
To operate our websites
To communicate with you
To create anonymous data for analytics
For compliance, fraud prevention, and safety
|These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).|
To comply with regulatory monitoring and reporting obligations
To comply with law
|Processing is necessary to comply with our legal obligations.|
|With your consent||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated when we requested the consent or by contacting us.|
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
You can submit these requests by email to email@example.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Whenever we transfer your personal information out of the European Economic Area (“EEA”) to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on safeguards that allow us to conduct the transfer in accordance with the EEA’s data protection laws.
Prolacta may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. The Federal Trade Commission has jurisdiction over Prolacta’s compliance with the Privacy Shield. Prolacta’s commitments under the Privacy Principles are subject to the investigatory and enforcement powers of the Federal Trade Commission.