SCIENTIFIC PROTEIN LABORATORIES 
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS 

Effective Date: , 2020 

Last Reviewed, 2020 

As used in this Privacy Notice for California Residents (this “Notice“), the terms “SPL,” “we,” “our,” and “us” each refer to Scientific Protein Laboratories LLC and its divisions, subsidiaries and affiliates. 

Introduction 

This Notice supplements the information and terms and conditions contained in our Privacy Policy and applies only to individuals who reside in the State of California (“consumers” or “you“). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended (the “CCPA). Any terms defined in the CCPA have the same meaning when used in this Notice. Capitalized terms not defined in the CCPA and used in this Notice without definition have the meaning given to them in our Privacy Policy. 

To the fullest extent permitted by the CCPA and other than where provided in this Notice, this Notice does not apply to personal information reflecting a written or verbal communication or transaction described in Cal. Civil Code § 1798.145(n) (“B2B Personal Information“).  

  1. Information We Collect 

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include: 

  • Publicly available information from government records. 
  • Deidentified or aggregated consumer information. 
  • Information excluded from the CCPA’s scope or from the CCPA’s definition of personal information, including, for example, personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. 

 

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:  

Category  Examples  Collected 
A. Identifiers.  A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.  [YES/NO] 
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).  A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. 

Some personal information included in this category may overlap with other categories. 

[YES/NO] 
C. Protected classification characteristics under California or federal law.  Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). 

 

[YES/NO] 
D. Commercial information.  Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.  [YES/NO] 
E. Biometric information.  Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.  [YES/NO] 
F. Internet or other similar network activity.  Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.  [YES/NO] 
G. Geolocation data.  Physical location or movements.   [YES/NO] 
H. Sensory data.  Audio, electronic, visual, thermal, olfactory, or similar information.  [YES/NO] 
I. Professional or employment-related information.  Current or past job history or performance evaluations.  [YES/NO] 
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).  Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.   [YES/NO] 
K. Inferences drawn from other personal information.  Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.  [YES/NO] 

 

We obtain the categories of personal information listed above from the following categories of sources: 

  • Directly from you, including without limitation when you: 
  • Inquire about our services and offerings; 
  • Contact us through the Site; 
  • Place an order; 
  • [Any other methods;] 
  • Complete and submit forms to us; or 
  • Provide us information when you conduct business with us; 
  • Indirectly from you, including without limitation by observing your actions on the Site. 
  • From an organization which you may have a relationship with, such as:  
  • your employer; 
  • [recruiters;] or 
  • a third party to whom you submit an application for employment with SPL. 
  • [[OTHER SOURCE CATEGORY].] 
  1. Use of Personal Information 

We may use or disclose the personal information we collect for one or more of the following purposes:  

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry and to otherwise conduct business with you 
  • [To provide, support, personalize, and develop the Site and our products and services.] 
  • [To process your requests, purchases, transactions, and payments and prevent transactional fraud.] 
  • [To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.] 
  • [To help maintain the safety, security, and integrity of the Site, our products and services, databases and other technology assets, and business.] 
  • [For testing, research, analysis, and product development, including to develop and improve the Site, products, and services.] 
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. 
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA. 
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of our Services and/or consumers is among the assets transferred. 
  • To engage in other activities in the normal course of [producing and supplying active pharmaceutical ingredients]. 

 

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

  1. Sharing Personal Information 

We may disclose your personal information to a third party for a business purpose 

[We do not currently share your personal information with any third parties./We share your personal information with the following categories of third parties:  

  • Service providers. 
  • [[Other Third-Party Category].]] 
  1. Disclosures of Personal Information for a Business Purpose 

In the preceding twelve (12) months, we [have not disclosed personal information for a business purpose/have disclosed the following categories of personal information for a business purpose 

[Category A: Identifiers.] 

[Category B: California Customer Records personal information categories.] 

[Category C: Protected classification characteristics under California or federal law.] 

[Category D: Commercial information.] 

[Category E: Biometric information.] 

[Category F: Internet or other similar network activity.] 

[Category G: Geolocation data.] 

[Category H: Sensory data.] 

[Category I: Professional or employment-related information.] 

[Category J: Non-public education information.] 

[Category K: Inferences drawn from other personal information.]] 

  1. Sales of Personal Information  

In the preceding twelve (12) months, we [have not sold personal information.]  

  1. Your Rights and Choices  

The CCPA provides consumers with specific rights regarding their personal information. This Section 4 describes your CCPA rights and explains how to exercise those rights. 

  1. Access to Specific Information and Data Portability Rights 

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you: 

  • The categories of personal information we collected about you. 
  • The categories of sources for the personal information we collected about you. 
  • Our business or commercial purpose for collecting that personal information. 
  • The categories of third parties with whom we share that personal information. 
  • The specific pieces of personal information we collected about you (also called a data portability request). 
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: 
  • sales, identifying the personal information categories that each category of recipient purchased; and  
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.  
  1. Deletion Request Rights  

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.  

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:  

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you. 
  1. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 
  1. Debug products to identify and repair errors that impair existing intended functionality. 
  1. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 
  1. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 
  1. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. 
  1. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 
  1. Comply with a legal obligation. 
  1. Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 
  1. Exercising Access, Data Portability, and Deletion Rights 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:  

  • Calling us at [TOLL-FREE NUMBER]. 
  • [Visiting [WEBSITE ADDRESS].] 
  • [Emailing us at [EMAIL ADDRESS].] 

 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: 

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. 
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  

  1. Response Timing and Format 

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.  

  1. Personal Information Sales Opt-Out Rights 

Under the CCPA, you have the right to direct a business which sells your personal information not to sell your personal information at any time (the “right to opt-out”). [We do not sell personal information.]  

  1. Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: 

  • Deny you goods or services. 
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. 
  • Provide you a different level or quality of goods or services. 
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. [We do not currently provide any financial incentives.] 

This Section 5 applies to B2B Personal Information. 

  1. Changes to this Notice 

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will [post the updated Notice on the Site (www.spl-pharma.comand update the Notice’s effective date]. Your continued use of the Site following the posting of changes constitutes your acceptance of such changes. 

  1. Contact Information 

If you have any questions or comments about this Notice, the ways in which we collect and use your information described here and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: 

Phone: 1-800-334-4775

Website: www.spl-pharma.com

Email: splcs@splpharma.com

Postal Address:  

Scientific Protein Laboratories LLC 

Attn: [CONTACT NAME/DEPARTMENT] 

[PHYSICAL ADDRESS] 

[[OTHER CONTACT METHOD]: [CONTACT INSTRUCTIONS]]