PRIVACY POLICY

1. Introduction

CDI Laboratories Inc. (“we” “us” or “our”) is committed to protecting and respecting your privacy. This policy (together with our Website Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be used by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of the CAN SPAM Act 2003 (the “Act”) and from May 25 2018 the General Data Protection Regulation (“GDPR”) and all relevant legislation implementing the same (the “Data Protection Laws”), the data controller is CDI Laboratories Inc., 12 W Mendez Vigo Avenue, Mayaguez, Puerto Rico USA 00680.

2. Information We May Collect From You and How We Use It

We may collect and process personal data about you when providing our core services, for example:

• Information such as your name, address and contact details, that you may provide when you fill in forms on our website www.cdilabs.com (our “Website”). This includes any form of registration to use our Website, subscribing to any of our services, posting material or requesting further services.
• We will use the information you give to us to answer your inquiry or request, or to notify you of any changes to our service. We do this on the basis that this is in our legitimate business interests in providing our service to you, and in answering any of your inquiries. We may also use the information you give to us if it becomes necessary to do so in order to carry out obligations arising from any contracts entered into between you and us.
• Information such as your name and email address, which you may provide when you report a problem with our Website. We will use this information to correspond with you in relation to the problem you have raised, and on the basis that this is in our legitimate business interests in ensuring that we provide you with a functioning Website.
• We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them. We will use the information that you provide to carry out our research activities and on the basis that by providing this information to us, you have given us your consent to use the information.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. We will use this information to deal with any payment or other issues and in accordance with our legitimate interest of providing our customer service to you.
• Details of your visits to our Website and the resources that you access. We will use this information to understand what products and services we offer are of interest to you, and on the basis that it is in our business interests to ensure that content from our Website is presented in the most effective manner for you and for your computer.
• Contact details and information including your CV that you may send to us in response to the Careers page or the Product Co-Development and Licensing section on our Website. We will use this information to assess your suitability for any jobs or other roles we may have available. We will do this on the basis that this is in our legitimate business interests to consider you as a candidate for employment with us.

We may also use your data for marketing and publicity purposes or to provide you with information about goods and services which may be of interest to you which we offer from time to time, and we may contact you about these. We will only do this where you have given us your consent. Where you have inquired about, or purchased products or services from us, we may contact you with details of our other products and services that we think may interest you. If you do not want us to use your data in the ways set out in this paragraph, or to pass your details on to third parties, please email us directly at [email protected]. Please see the relevant pages of our Website.

3. How Long We Hold You Information For

We will only hold your information for as long as is necessary for the purpose we have collected it for, plus a period of time to allow us to deal with any follow up issues that may arise. This will typically be for 6 years.

Typically, where we provide services to you, or you purchase goods from us, we will hold your information for the duration of our engagement or until the goods are received by you, and for a period of 6 years after the date that those goods or services are no longer offered by us to enable us to deal with any payment or follow up issues that may arise.

If you ask to register for updates from us, we will hold your information until you tell us that you no longer wish to be subscribed, or to receive our updates.

For the purposes of direct marketing by us information will be retained on our marketing database until we receive an opt-out from you or until we decide that there is no longer a ‘legitimate interest’ in retaining the information, for whatever reason.

4. IP Addresses and Cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is mainly statistical data about our users’ browsing actions and patterns, but some information may be personal data for the purposes of Data Protection Laws.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. We collect information and use cookies on the basis that this is in our legitimate interests in helping us to improve our Website for its users and to deliver a better and more personalized service to you.

Cookies enable us to:

• estimate our audience size and usage pattern;
• store information about your preferences, and to allow us to customize our Website according to your individual interests;
• speed up your searches; and
• recognize you when you return to our Website

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Website. Please note that our advertisers may also use cookies, over which we have no control.

5. Where We Store Your Personal Data

The data that we collect from you may be transferred to, and stored at, a destination outside the United States. It may also be processed by staff operating outside of the United States who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. This is also undertaken in our business interests in order to perform certain functions where we have appointed third party service providers.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Where we have given you (or where you have chosen) a username and password which enables you to access certain parts of our Website, you are responsible for keeping this username and password confidential. We ask that you do not share your username and password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

6. Disclosure of Your Information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may also disclose your personal information to our employees and third parties such as our officers, agents, suppliers or subcontractors in so far as it is reasonably necessary for the purposes as set out in this Privacy Policy, for example:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if CDI Laboratories Inc. is (or substantially all of its assets are) acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website terms and conditions of supply and other agreements; or
• to protect the rights, property, or safety of CDI Laboratories Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction which is part of our proper business function.

7. Your Rights

If you do not wish us to collect and use your personal data as set out in this Privacy Policy then you should not send any such data to us.

You have the right to ask us not to process your personal data for direct marketing purposes at any time. We will inform you before collecting your data if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and seek your consent as appropriate. Please note that unless you consent to our use of your data for these purposes you can withdraw that consent whenever you wish.

We are obliged to ensure that the information we hold about you is accurate and up to date. You have a right to ensure that any inaccuracies in your personal data are corrected or removed by us. We will promptly correct any information found to be incorrect. You also have the right to require us to provide your personal data in a portable format, and in some circumstances, to ask us to erase it.

Where we have stated that we may use your personal data on the basis of ‘our legitimate interests,’ you have a right to object to us processing your information on this basis. You can also exercise any of your rights at any time by contacting us using the details set out below. You also have the right to raise any concerns about the way in which we handle your personal data with the Federal Trade Commission (FTC).

8. Links to Other Websites

Our Website may, from time to time, contain links to and from the website of advertisers, affiliates and relevant third parties. If you follow a link to any of these website, please note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites, and such sites are not governed by this Privacy Policy. Please exercise caution and check the privacy policies applicable to the websites in question before you submit any personal data.

9. Access to Information

Under Data Protection Laws you have the right to access any personal data we hold about you. You can ask us to confirm if we are using any of your personal data, to give you a description of the data we are processing and/or to send you a copy of it. You can request this from us at any time by writing to: CDI Laboratories Inc., Request for information, P.O. Box 569, Mayaguez, PR 00681-0569

10. Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page. You should check this page occasionally to ensure that you are happy with any changes.

11. General

If a provision of this Privacy Policy is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect. If any unlawful and/or unenforceable provision would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.

12. Contact

Questions, comments and requests regarding this Privacy Policy or our treatment of your personal data are welcomed and should be sent to [email protected] or alternatively you can contact us by telephone at +1 939-280-5293.