Locke BioPrivacy Policy


Last updated and effective as of December 7, 2021



This Privacy Policy explains how information about you is collected, used and disclosed by Tuolc, Inc. (operating as “Locke Bio”) and our corporate affiliates, including without limitation any subsidiaries, and our professional entities that employ or engage healthcare providers (collectively, “Locke Bio”, “we”, “us” or “our”). This Privacy Policy applies to information we collect when you use our (a) website located at www.lockebio.com (the “Website”); (b) our application programming interface, access tokens, HTML scripts, code snippets, tools, instructions, documentation, and other materials made available by Locke Bio (collectively, the “Locke Bio API”); and (c) any other services owned or operated by Locke Bio which link to this Privacy Policy (collectively, the “Services”).



This Privacy Policy does not apply to information that is protected health information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”). Any collected information that constitutes PHI is governed by, and will be used and disclosed solely as permitted under, the business associate agreement between Locke Bio and your healthcare provider (each, a “Provider”), as required by law, to safeguard PHI. For more information about the privacy of PHI, please contact your Provider. Any information provided directly to a Provider is treated in accordance with that Provider’s notice of privacy practices, and we encourage you to ask the Provider for information about their practices before providing any information to them.


We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed of our information practices and the ways you can help protect your privacy.


By accessing or using the Services, you consent to our collection, use, and sharing of your information in accordance with this Privacy Policy. This Privacy Policy is not a contract and does not create any contractual rights or obligations.



Collection of Information 

As used in this Privacy Policy, “Personal Information” means any information that can be used to individually identify a person or household, and may include, but is not limited to, name, email address, postal or other physical address, title, and other information reasonably linkable to an individual or household with or without other identifying information in our possession. Personal Information also includes information relating to a person’s professional background, and may include, but is not limited to, resume, educational history, professional specialty, professional licenses and/or certifications, geographic areas of professional practice, legal claims relating to professional background, and years of professional experience.




Information You Provide to Us


We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services, fill out a form, request customer support, apply for a job with us, or otherwise communicate with us.


The types of information we may collect from you include:



Information We Collect When You Use the Services


When you access or use our Services, we automatically collect information about you, including:


Information We Collect from Other Sources

We may obtain information from other sources and use it as contemplated herein, including to provide the Services to and otherwise communicate with you.




Use of Information


We may use information about you for various purposes, including to:



We also may use aggregated or de-identified information, which cannot reasonably be used to identify you, for various purposes, including, for example, to improve our automation and improve care. Once aggregated or de-identified, the data does not personally identify you, is no longer personal information, and is not subject to this Privacy Policy.



Sharing of Information


We may share information about you as follows or as otherwise described in this Privacy Policy:


Third-Party Analytics


From time to time, we may partner with certain third parties, such as Google Analytics, to collect, analyze, and use some of the information described above. For example, we may allow third parties to set cookies or use web beacons on the Services or in email communications from Locke Bio . The information collected by third parties using these technologies may be used to engage in analysis and reporting. These third parties may set and access cookies on your computer or other device and may collect information about your online activities across different websites or services over time, including on websites and mobile applications that are not owned or operated by Locke Bio . You may review Google Analytics’ security and privacy principles by clicking here and opt out of the use of cookies in web browsers by Google Analytics by clicking here.




Links to Third Party Sites 


Our Services may contain links to other web sites. Other web sites may also reference or link to our Services. These other web sites are not controlled by Locke Bio . We encourage our users to be aware when they leave our Services to read the privacy policies of each and every web site that collects personally identifiable information. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other web sites or mobile applications. Visiting these other web sites is at your own risk.



Security


While Locke Bio takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction, please be advised that when information is transmitted over the internet, it cannot be guaranteed to be completely secure.


How We Respond to "Do Not Track" Signals


Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. At present, our Services do not respond to “Do Not Track” signals and consequently, the Services will continue to collect information about you even if your browser’s “Do Not Track” feature is activated.



Note to International Users


The Services are intended for use in the United States of America only. If you access our Services or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America; and (ii) that by accessing our Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.



Your Choices

Account Information 

You may update, correct, or delete information about you at any time by logging into your account or by emailing us at support@lockebio.com. If you wish to deactivate your account, you may do so by logging into your account and selecting that option under Account Settings, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.


Promotional Communications

You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at support@lockebio.com. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.


Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services.ove or reject cookies, this could affect the availability and functionality of the Services.



California Residents


California Shine the Light: Residents of the State of California have the right to request information from Locke Bio regarding other companies to whom the company has disclosed certain categories of information during the preceding year for the other companies' direct marketing purposes. If you are a California resident and would like to make such a request, please email privacy@lockebio.com.



California Consumer Privacy Act: The California Consumer Privacy Act ("CCPA") provides California residents with the right to receive certain disclosures regarding the collection, use, and sharing of "Personal Information," as well as the right to know/access, delete, and limit sharing of Personal Information. The CCPA defines "Personal Information" to mean "information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household." Certain information we collect may be exempt from the CCPA because it is considered public information (e.g., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.




Right to notice at collection regarding the categories of personal information collected


You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.


Personal identifiers: We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities. If you provide us with your name, phone number, and email, then we will collect those personal identifiers as well. We use this information to notify you of work opportunities should one arise. We may collect your Social Security number or Driver's License number. We use this information to identify you, authenticate and collate information about you, prevent fraud, and conduct background checks or other screening activities.


Geolocation data: As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device's IP address. When you use the Services for the first time, we may ask for your permission to collect your precise location (i.e., your GPS coordinates).


We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.


We may share any of the above-listed information with Service Providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service Providers are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of Service Providers with whom we share information and the services they provide are described in this Privacy Policy.


Protected classifications: We collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors.



Right to know about personal information collected, disclosed, or sold


You have the right to request that we disclose to you the Personal Information we collect, use, disclose, or sell. In order to process your request to know/access your Personal Information or delete your Personal Information we may ask you to take additional steps to verify your request or identity.




Verification procedures


In order to process your request to know about or delete personal information we collect or disclose, we must verify your request. We do this by providing personal identifiers we can match against information we may have collected from you previously. 


If you have authorized someone else to make requests on your behalf, we will require that you provide notarized statements confirming the identity and authority of that person. Such notarized statements can be obtained by emailing privacy@lockebio.com.



Right to know/access information


You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers' Personal Information, we are required to verify your identity before we can act on your request.


Right to request deletion of information


You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers' Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.


Right to information regarding participation in data sharing for financial incentives


You have the right to be free from discrimination based on your exercise of your CCPA rights. We may run promotions from time to time wherein we incentivize a consumer to share certain pieces of information with us. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.


Right to opt out of sale of personal information to third parties


Locke Bio  does not offer an opt-out from the sale of personal information because Locke Bio does not engage in the sale of personal information as contemplated by the CCPA. As noted elsewhere in this disclosure, we share personal information with other businesses for a variety of reasons. While we often benefit from such exchanges, we do not share personal information for the sole purpose of receiving compensation for that information.


How to submit a request 


You may submit a request to exercise your rights by emailing privacy@lockebio.com, where you can request and download specific pieces of information we have collected.



Authorized agent 


You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf.



Children's Online Privacy Policy 


Locke Bio  is committed to protecting the privacy of children who use our site. The Children’s Online Privacy Protection Act (“COPPA”) protects children under age 13 (“Children”). Locke Bio does not knowingly collect any personal information (as that term is defined in the COPPA) from children under the age of 13 through our website. If you think we have collected such personal information from a child under the age of 13 through our website, please email our Privacy Officer at privacy@lockebio.com