Next Level Genomics Group

Privacy Policy

Next Level Genomics Pte Ltd. (hereinafter referred to as NLG) respects your privacy and is committed to protecting your personal data. This privacy policy, or Personal Data Protection Policy, will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Please also use the glossary to understand the meaning of some of the terms used in this privacy policy.

General information about us
What data do we collect, and how do we collect it?
How we might use your personal data
Disclosures of your personal data
International transfers
Data security
How long will your personal data be used?
Your legal rights
Glossary

1. Important Information and Who We Are

The Purpose of this Privacy Policy
This privacy policy aims to give you information on how NLG and our group companies collect and process your personal data, including any data you may provide through our websites, when you use our services, or when you request to receive information from us.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller
NLG is made up of different legal entities, details of which can be found in the glossary. This privacy policy is issued on behalf of the NLG Group, so when we mention “Next Level Genomics,” “NLG,” “we,” “us,” or “our” in this privacy policy, we are referring to the relevant company in the NLG Group responsible for processing your data. We have appointed a data protection officer (DPO) in each country who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

If you have any questions, comments, or concerns about the Privacy Policy or our processing activities, regardless of your country or region, please email us or our data protection officer at the following address: [email protected].

You have the right to make a complaint at any time to the relevant data protection supervisory authority, as listed below, depending on your location. We would, however, appreciate the chance to deal with your concerns before you approach your relevant supervisory authority, so please contact us in the first instance.

Changes to the Privacy Policy
We may update this privacy policy from time to time in response to changing legal, technical, or business developments. When we update our privacy policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes to this privacy policy if and where this is required by applicable data protection laws. You can see when this privacy policy was last updated by checking the “last updated” date displayed at the top of this policy.

Third-Party Links
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.

2. What Data and How We Collect Your Data.

What Data Do We Collect
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 as follows:

Identity Data includes first name, last name, username, or similar identifier, and job title.
Contact Data includes billing address, delivery address, email address, and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes the 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 our websites.
Profile Data includes your username and password, purchases or orders made by you or your business, your interests, preferences, feedback, and survey responses.
Usage Data includes information about how you use our websites, products, and services.
Marketing and Communications Data includes your preferences for receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

How Do We Collect Your Data
We use different methods to collect data from and about you, including:

Direct Interactions. You may give us your identity, contact information, and financial data by filling out forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you: You may give us your identity, contact information, and financial data by filling out forms or by corresponding with us by post, phone, email, or otherwise.
This includes personal data you provide when you:
- Apply for our services.
- Subscribe to our service or publications.
- request marketing to be sent to you, or
- Give us feedback or contact us.
Automated Technologies or Interactions. As you interact with our websites, we may automatically collect technical data about your equipment, browsing actions, and patterns. We may collect this personal data by using cookies, server logs, and other similar technologies.
Third Parties or Publicly Available Sources. We will receive personal data about you from various third parties, as set out below.
- Anonymized data from our clients.
- Technical data from the following parties:
  - analytics providers
  - advertising networks, and
  - search information providers
- Contact, financial, and transaction data from providers of technical, payment, and delivery.
- Identity and contact data from data brokers or aggregators.

3. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

We need to perform the contract we may or may not have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights, do not override those interests.
Where we need to comply with a legal obligation.

Read below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data, although we will seek your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data
We have set out below, in table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful reason, depending on the specific purpose for which we are using it. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data, where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our websites, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Promotional Offers from NLG
We may use your identity, contact, technical, usage, and profile data to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, and you have not opted out of receiving that marketing.

Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out
Unless you tell us otherwise by “unsubscribing” or “opting out,” we may also contact you regarding other products, services, and related information that may be of interest to you. You can exercise your right to prevent such contact by setting your preferences on the site or sending a letter to NLG at the address set forth in the Controller section. Please note that you may not unsubscribe or opt-out of account management communications (e.g., billing, status emails, support issues).

Cookies
Our website may use cookies to distinguish you from other users of our website. This helps us provide you with a good experience when you browse our website and allows us to improve it. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. You may set your browser software to reject cookies, but please note that some parts of our websites may become inaccessible or not function properly.

Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Failure 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 that time.

4. Disclosures of Your Personal Data

We may share your personal data with the parties listed below for the purposes set out in the table above.

Internal Third Parties as set out in the “Glossary”.
External Third Parties as set out in the “Glossary”.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International Transfers

We may share your personal data within the NLG Group. NLG Group is headquartered in Singapore and has affiliated companies located across Asia. For a complete list of NLG affiliated companies, please refer to the Glossary section of this Privacy Policy. Although the laws of such countries or territories may not offer the same level of data protection as the country where you reside, NLG seeks to utilize the same standards, at least as restrictive as the standards of the Singapore Personal Data Protection Act and those stated in this Privacy Policy, when dealing with and transferring your data.

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances, you can ask us to delete your data; see “Your legal rights” below for further information.

8. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request for Access
You have the right to access your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request for Correction
You have the right to request a correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request to Erase
You have the right to request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

Object to Processing
You have the right to object to the processing of your personal data where we are relying on legitimate interests (or those of a third party), and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object if we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

Request Restriction of Processing
This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy,.
Where our use of the data is unlawful but you do not want us to erase it.
You need us to hold the data even if we no longer require it, as you need it to establish, exercise, or defend legal claims.
You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request to Transfer Data.
You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw Your Consent at Any Time.
Where we are relying on consent to process your personal data, you can withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please email us or our data protection officer at the address set forth in the Controller section.

No Fee is Usually Required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request and speed up our response.

Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

9. Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service or product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Complying with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties
Internal Third Parties.
Affiliated companies in the NLG Group acting as joint controllers or processors of your data:

Country or Region	NLG Affiliated Company
Singapore	NLG Pte Ltd
USA	NLG LLC

External Third Parties

Service providers act as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers include lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
Internal Revenue Service (IRS), regulators, and other authorities acting as processors or joint controllers based in the United States who require reporting of processing activities in certain circumstances.

Email Privacy
When you communicate with us over email, we process your data for communication purposes, and we store this data in our systems. Your data is processed in order to communicate with you, provide you with information about our products and company, or process your inquiry and respond to your requests.
You have the right to object to the processing at any time for reasons arising out of your situation. We will then no longer process your personal data unless there are demonstrably compelling grounds for processing that override the interests, rights, and freedoms of the data subject or the processing serves the purpose of asserting, exercising, or defending legal claims.
Any email communication based on a contract will be deleted as it is no longer needed for the performance of the contract or as soon as the contract is terminated and legal retention periods have expired.
Our company is part of an international group of companies in which responsibilities exist across departments, companies, and national borders. For this reason, we may transfer personal information across borders. This only happens if appropriate safeguards are in place (see above, Transfers of Information).

Consent
In providing personal information to NLG Group through the site or by using our products or services, you are consenting and agreeing to our collection and use of private data in accordance with this privacy policy.

Linked Websites
This policy does not apply to any third-party websites linked to the site or that may provide links to the site. Any use of such third-party websites shall be governed by the privacy and other policies of such other websites, and Pacific Biosciences accepts no responsibility for the privacy and/or security of any information you may submit to any third-party websites.

Data Sharing
Please remember that any content you or any user uploads to our services may be publicly available to other users by default and may be collected and used by these other users, transferred, or made public without our consent. Be careful not to include or attach any identifiers, including, for example, labeling a file with an individual’s name, identifier, date of service, or other similar information. Any use or further disclosure of any content by another user of our services is not a use or disclosure by us. We do not control the policies and practices of any third-party sites or services. Additionally, when you share information with third parties, that information may be passed along or made public by others. Therefore, anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

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