This Privacy Notice (“Notice”) describes how ADVANCED BACTERIAL SCIENCES (ABS) and its affiliates (collectively referred to as “ABS”, “we”, “us” or “our”) collects, uses and shares personal data collected in the context of our websites, business contacts, suppliers, current and prospective customers who use ABS services or products or users affected by our services (together referred to as “you” or “your”).

This Notice also explains your ability to edit, update, correct, or delete your personal data and the security procedures that we have implemented to protect personal data.

1. Important information

1.1 Purpose

This privacy notice aims to give you information on how ABS collects and processes your personal data, the purposes for which we use this and the way in which the data is handled.

It is important to read this privacy notice together with any other privacy or fair processing notice we may provide on specific occasion, for example where you or the business you work for engages us to provide a service.

1.2 Controller

The ABS is the controller and responsible for your personal data. If you have any questions in relation to this privacy notice including any request to exercise your rights please contact us.

2.0 The data we may collect from you:

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

1. 2.1 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2. 2.2 Contact Data includes billing address, delivery address, email address and telephone numbers. Financial Data includes bank account and payment card details.
3. 2.3 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
4. 2.4 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
5. 2.5 Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
6. 2.6 Usage Data includes information about how you use our website, products and services.
7. 2.7 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
8. 2.8 We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
9. 2.9 We do not collect any Special Categories of Personal Data or sensitive personal about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.]

3.0 When we collect personal data

We may collect personal data about you if you:

• use one of our websites or online services (Website Users);
• contact us to discuss our services;
• purchase one of our services (Customers);
• are affected by our services (Users);
• work with us as a business partner (Business Partners);

4.0 If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

5.0 How is your data collected?

We use different methods to collect data from and about you including through:

1. 5.1 Direct interactions
   You may give us your Identity, Contact, Employment and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
   • apply for our services;
   • receive our services;
   • supply services to us;
   • submit an enquiry on our website;
   • open an account on our website;
   • subscribe to our service or publications;
   • request marketing to be sent to you;
   • enter a competition, promotion or survey; or
   • give us some feedback.
2. 5.2 Automated technologies or interactions.
   As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
   • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
     • Technical Data from inside or outside the EU from the following parties:
       • analytics providers
       • advertising networks
       • search information providers
     • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based
     • Identity and Contact Data from data brokers or aggregators based
     • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register

6.0 How we use your data

We will collect personal data from you, your representative and/or your contact person such as your full name, job title, email address, phone number.

Most of the personal data is obtained directly from you. In addition, we will collect personal data from other public sources such as credit reference agencies.

We use this information to review/assess your suitability as a Business Partner or service provider, to comply with our legal obligations, to detect investigate, report, and seek to prevent fraud and anti-money laundering, for example through know- your-customer checks, AML screening and other identity checks and to meet our obligations under any contracts we have with you, we may also need to conduct credit and fraud checks on your business and certain officers of your business, such as directors.

Emails
If you send to, or receive emails from us, we may monitor their content to ensure compliance with our internal policies and to protect our business.

7.0 Legal basis for the processing

We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do this. Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

1. 7.1 Your consent. You are able to remove your consent at any time. You can do this by contacting hello@abs.co.uk
2. 7.2 We have a contractual obligation.
3. 7.3 We have a legal obligation.
4. 7.4 We have a vital interest.
5. 7.5 We need it to perform a public task.
6. 7.6 We have a legitimate interest

In most of the cases, the provision of your personal data is not required by a statutory or contractual obligation. However, where applicable, the provision of your personal data will be necessary to enter into a contract with ABS or to receive our products as requested by you.

If you would like to find out more about the legal basis for which we process personal data, please contact us at hello@abs.co.uk

8.0 Marketing

We may use personal data to let you know about our products services that we believe will be of interest to you and/or provide you with our newsletter. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

As a rule, we will obtain your consent prior to sending you marketing materials. We will only contact you with marketing materials without your prior consent if this is permitted by law.

How you can manage your marketing preferences

To protect privacy rights and to ensure you have control over how we manage marketing with you:

• we will take steps to limit direct marketing to a reasonable and proportionate level and ABS will only send you communications which we believe may be of interest or relevance to you;
• you can ask us to stop direct marketing at any time you can ask us to stop sending email marketing, by contacting us on hello@ABS.co.uk. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email); and
• you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser.
• How we share information within ABS and with our service providers, regulators and other third parties

8.1 We share your personal data in the manner and for the purposes described below:

• With other ABS entities within our group
• With third parties who help manage our business and deliver services ABS engages external service providers such as legal services, website service providers, marketing service providers, IT support service providers, fulfilment providers, delivery service providers, email administrators and payment processors. When providing such services, the external service providers have access to and process your personal data. As part of our due diligence we to ensure these companies have adequate security protocols in place for the privacy and security of your personal data. These third parties have agreed to confidentiality restrictions and to use of any personal data we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us.
• In the event of a corporate merger and acquisition, your personal data will be transferred to the third parties being involved in the merger and acquisition in accordance with applicable law.

8.2 Cookies and third-party links

ABS websites use cookies. Generally, we use cookies to understand how our services are used, track bugs and errors, improve our services and track sessions as well as for targeted marketing and advertising, to personalise content and for analytics purposes. For further information contact hello@abs.co.uk

Our websites contain links to websites operated and maintained by third parties over which ABS has no control. Any information you provide to third-party websites will be governed under the terms of each website’s privacy policy, and we encourage you to investigate and ask questions before disclosing any information to the operators of third-party websites. We have no responsibility or liability whatsoever for the content, actions, or policies of third-party websites. The inclusion of third-party websites on our site in no way constitutes an endorsement of such websites’ content, actions, or policies.

9.0 How we store and protect personal data

9.1 How long does ABS keep your personal data?

Your Personal Data will be retained as long as it is required for the purposes for which the data is collected e.g. as necessary to provide you with the services and products requested. Once you have terminated the contractual relationship with us and/or you have deleted your account, or, in case you are a User, following the termination of the contractual relationship in the scope of which your personal data was processed, we will permanently remove your personal data unless statutory retention requirements apply (such as for taxation purposes, dosimetry purposes or professional training purposes) or in order to fulfil regulatory requirements. We retain your contact details and interests in our products or services for a longer period of time if ABS is allowed to send you marketing materials. We also retain your personal data if needed to establish, exercise or defend a legal claim, on a need to know basis only.

9.2 Personal data security

We have adopted appropriate data collection, storage and processing practices, technical, organisational and security measures designed to protect against unauthorised access, alteration, disclosure or destruction of the personal data that you share with us. For example, such measures include:

• placing confidentiality requirements on our staff members and service providers;
• permanently removing personal data if it is no longer needed for the purposes for which it was collected;
• following security procedures in the storage and disclosure of your personal data to prevent unauthorised access to it; and

10.0 Your data protection rights

As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

Your data protection rights
Under data protection law, you have rights including:

Your right of access– You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing– You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability– You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at hello@abs.co.uk if you wish to make a request.

You also have a right to complain to the UK Information Commissioner’s Office by visiting ico.org.uk, or to the data protection regulator in the country where you live or work.