Privacy Policy

Ochre Bio Limited and its affiliates (“Ochre Bio,” “we,” “our,” and/or “us”) value the privacy of individuals who use our website (“Website”), the Obelix Software, and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose information from users of our Services (“Users”). As used in this Privacy Policy, “information” means any information relating to an identified or identifiable individual. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to and must be used in accordance with our Terms of Service.

If we are providing the Services to you on behalf of a third-party partner (such as your employer) who has paid (in whole or in part) for you to use the Services, we will abide by the terms of our agreement with that third-party partner related to the collection, use, and disclosure of your information.

Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below. Where applicable, we indicate whether and why you must provide us with your information, as well as the consequences of failing to do so.

If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.

A. Information You Provide to Us.

Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, the contents of a message or attachments that you may send to us, and other information you choose to provide.

Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn.

B. Information We Collect When You Use Our Services.

Device Information. We receive information about the device and software you use to access our Services, including IP address (which may provide us with your general location information), web browser type, operating system version, and device identifiers.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view and the dates and times of your visits. We do not collect information about the pages or other content you view on the Obelix Software.

Information from Cookies and Similar Technologies.  We and our third-party partners may collect information on our Website using cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer.  They contain information that is transferred to your computer’s hard drive.  We and our third-party partners may also use pixel tags and web beacons on the Website.  These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action.  We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies”) on our Website to collect information about your browsing activities and to distinguish you from other users of the Website.  This aids your experience when you use the Website and allows us to improve the functionality of the Website.  Cookies can be used for performance management (i.e., collecting information on how the Website is being used for analytics purposes).  They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details.  Below is an overview of the types of Cookies we and third parties may use to collect information.

• Strictly Necessary Cookies. Some Cookies are strictly necessary to make the Website available to you.  We cannot provide you with the Services without this type of Cookies.  We use the following necessary Cookies:

Name	More Information	Retention
elementor	Used in context with the Website’s WordPress theme. This cookie allows the Website owner to implement or change the Website’s content in real-time.	Persistent

• Analytical or Performance Cookies. We also use Cookies for website analytics purposes to operate, maintain and improve the Website.  We may use our own analytics Cookies or use third-party analytics providers such as Google Analytics.  Google uses the data collected to track and monitor the use of our Website. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.  We also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.  These providers may also collect information about your use of other websites, apps, and online resources.  We also use the following analytical or performance Cookies:

Name	More Information	Retention
_ga_*	Contains a unique identifier used by Google Analytics 4 to determine that two distinct hits belong to the same user across browsing sessions.	A year
_ga	Contains a unique identifier used by Google Analytics to determine that two distinct hits belong to the same user across browsing sessions.	A year

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings.  Please note that if you delete or choose not to accept cookies from the Website, you may not be able to utilize the features of the Website to their fullest potential.  You can find more information about your rights and choices, and how to block the use of certain Cookies in the section Your Rights and Choices below.

We do not use cookies on the Obelix Software.

C. Information We Receive from Other Sources.

Information from your employer. We may receive certain employment-related information about you from your employer, such as your name, job title, and email address, to verify that you are eligible to use the Services on behalf of your employer.

How We Use the Information We Collect

We use the information we collect:

• To provide, maintain, improve, and enhance our Services;
• To personalize your experience on our Services such as by providing tailored content and recommendations;
• To understand and analyze how you use our Services and develop new products, services, features, and functionality;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• For marketing purposes, such as developing and providing promotional materials that may be relevant, valuable or otherwise of interest to you;
• To generate anonymized or aggregate data containing only de-identified, non-personal information that we may use for any lawful purposes such as to publish reports;
• To find and prevent fraud and abuse, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected.

Legal Bases for Processing European Information

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we only process your information when we have a valid “legal basis,” including as set forth below.

• Consent. We may process your information where you have consented to certain processing of your information.  For example, we may process your information to use Cookies where you have consented to such use.
• Contractual Necessity. We may process your information where required to provide you with the Services.  For example, we may need to process your information to respond to your inquiries or requests.
• Compliance with a Legal Obligation. We may process your information where we have a legal obligation to do so.  For example, we may process your information to comply with tax, labor and accounting obligations.
• Legitimate Interests. We may process your information where we or a third party have a legitimate interest in processing your information.  Specifically, we have a legitimate interest in using your information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Services.  We only rely on our or a third party’s legitimate interests to process your information when these interests are not overridden by your rights and interests.

 

How We Disclose the Information We Collect

We do not disclose information we collect from or about you except as described below or otherwise disclosed to you at the time of the collection. 

Vendors and Service Providers. We may disclose any information we receive to vendors and service providers retained in connection with the provision of our Services.

Analytics Partners. We use analytics services such as Google Analytics and Cloudflare Insights to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Consent. We may also disclose your information with your permission.
 

Your Rights and Choices 

Your European Privacy Rights.  If you are located in the EEA or the UK, you have additional rights described below.

• You may request access to the information we maintain about you, update, and correct inaccuracies in your information, restrict or object to the processing of your information, have your information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• You may withdraw any consent you previously provided to us regarding the processing of your information at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy.  Before fulfilling your request, we may ask you to provide reasonable information to verify your identity.  Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

How to Block Cookies.  You can block Cookies by setting your internet browser to block some or all Cookies.  However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Services.  By using the Services, you consent to our use of Cookies and our processing of information collected through such Cookies, in accordance with this Privacy Policy.  You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser, or as explained below.  You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse the Services using your browser’s anonymous usage setting.  Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.  If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly.  You should understand that some features of the Services may not function properly if you do not accept Cookies or these technologies.  Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.

If you choose not to provide us with information we collect, some features of the Services may not work as intended.

Data Retention

We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies and in accordance with applicable laws. To determine the appropriate retention period for your 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 use your personal information and whether we can achieve those purposes through other means, and applicable legal requirements.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security  

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Service(s) is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at contact@ochre-bio.com.

International Visitors

Our Services are hosted in the United Kingdom and the European Economic Area. If you choose to use the Services from other regions of the world with laws governing data collection and use, then please note that you are transferring your personal information outside of those regions to the UK and the EEA for storage and processing. We may transfer information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved or UK Government-approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws.  We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing. For more information about the tools that we use to transfer information, you can contact us as described below. 

Delete Your Account

You can request that we delete your Obelix Software account by sending a message to your employer’s software administrator. We will comply with any requests from your software administrator to delete your account.

Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

Contact Information

Ochre Bio is responsible and the data controller for processing your information. If you have any questions, comments, or concerns about our processing activities, please email us at contact@ochre-bio.com or write to us at Ochre Bio, Hayakawa Building, Edmund Halley Rd, Oxford OX4 4GB, United Kingdom.

 

Last Updated: June 24, 2024