Introduction
Our privacy policy (the Privacy Policy) explains the information We collect, how we use and share it, how to manage your privacy controls to the extent you sign-up for an account and make use of our platform, and your rights in connection with our Website and platform (collectively, the Services). Please also read our terms of service (the Terms of Service), available here, which sets out the terms governing the Services.
Cradle is headquartered in Delft, the Netherlands and our Services are provided to you by Cradle Bio B.V., a company registered with the Dutch Chamber of Commerce under 84219092, having its place of business at Alexander Fleminglaan 1, 2613 AX, Delft, the Netherlands (Cradle, We or Us).
Questions or comments about this Privacy Policy may be submitted by e-mail to legal@cradle.bio
Information Cradle may process
We collect information about you, including information that may directly or indirectly identify you, if you choose to share it with us. We receive information in a few different ways, including when you create an account. If you create an account, We also collect information about how you use the Services. The information We collect is the following:
2.1. If you register for our platform: account, profile, and use Information
Upon registering, We collect basic account information such as your name, email address, username and password that helps secure and provide you with access to our Services.
2.2. Detailed activity and use information
We collect this information about how you use the Services to improve our products.
2.3. Your contact information
We use your contact information so We can respond to your support requests and comments.
2.4. Technical information
We collect information from your browser, computer, or mobile device, which provides us with technical information when you access or use the Services. This technical information may include device and network information, cookies, log files and other analytics information.
2.5. Other information
We may collect information from you through third parties, such as when We collect your feedback through surveys. The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), platform type, date/time stamp, and other relevant analytics information. This information is used to analyze trends, administer, protect and secure the Services. IP addresses may be linked to session IDs and device identifiers
Our legal basis for processing your information
Cradle relies on a number of legal bases to collect, use, share, and otherwise process the information We have about you for the purposes described in this Privacy Policy, including:
as necessary to provide the Services and fulfil our obligations pursuant to the Terms of Service and/or any contract You and We enter into. For example, We cannot register your account unless you provide us with basic account information (such as email address, name);
where you have consented to the processing;
where necessary to comply with a legal obligation of whatever nature (including any compliance obligations), a court order, to prevent or limited any damages that We might sustain, or to exercise and defend legal claims; and
where necessary for the purposes of Cradle’s or a third party’s legitimate interests, such as Our commercial interests in ensuring the sustainability of the Services.
How Cradle uses your information
We use the information We collect and receive to provide the Services for the following objectives:
4.1. To provide the Services
We use the information We collect and receive to provide the Services, including providing you with the ability to upload sequences, train machine learning models on your data and analyze results.
4.2. To customise your experience
We use the information We collect about you and your activities to customise your experience. For example, We may suggest new features that may interest you. We are processing this data on the basis of our Terms of Service and in furtherance of our legitimate business interests to offer you the most optimal possible Service.
4.3. To protect the Services
We use the information We collect to enforce our Terms of Service. For example, We find and remove events and/or accounts that violate Our terms.
4.4. To improve our Services
We also use the information We collect to analyze, develop and improve the Services. To do this, Cradle may use third-party analytics providers to gain insights into how Our Services are used and to help Us improve the Services. We are processing this data on the basis of our Terms of Service and in furtherance of our legitimate business interests to offer you the most optimal possible Service.
4.5. To communicate with You
We use the information We collect to provide support in response to your requests and comments. We process this data in accordance and to effect our Terms of Service.
Affiliates and acquirors of our business or assets
We may share your information with affiliates under common control with Us, who are required to comply with the terms of this Privacy Policy with regard to your information. If Cradle becomes involved in a business combination, shares offering, bankruptcy, reorganisation, dissolution or other similar transaction, We may share or transfer your information in connection with such transaction. If We engage advisors in relation to a potential transaction, they are obliged to comply with the conditions in this Privacy Statement. When there are changes in the way your personal data is handled, We will first communicate this to you.
Protection of your information
We take several measures to safeguard the collection, transmission and storage of the data We collect. We employ reasonable protections for your information that are appropriate to its sensitivity.
Third party service providers
We may share your information with third parties who provide services to Cradle such as supporting, improving, promoting and securing the Services, or processing payments. These service providers only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information.
Your rights
You can request Us to exercise your rights with regard to your personal data:
8.1. Withdrawing permission.
Where you have previously provided your consent, such as to permit us to create an account on your behalf, you have the right to withdraw your consent to the processing of your information at any time.
8.2. Access to processing information.
You can ask Us which personal data We process from you. If We do so, We will share with you which personal data is processed, with what purpose, with which third parties it is shared, the storage periods used, the source of which personal data may have been collected from outside of you and information about any automated decision-making, if any.
8.3. Rectify, restrict, limit, delete.
You can also rectify, restrict, limit or delete much of your information by logging into your account. You can also contact Us if you’re unable to do so yourself. Furthermore, you can request Us to limit the processing of your personal data when the correctness of the personal data is disputed, the processing of personal data is unlawful but you do not want it to be deleted, or if you are waiting for the response on a request for exercising the right of objection. In that case, We still store the data, but We do not process it further.
8.4. Objection
Where We process your information based on our legitimate interests, you can object to this processing in certain circumstances. In such cases, We will cease processing your information unless We have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
8.5. Data transfer (data portability)
You can request Us to obtain your personal data in a structured, current and machine-readable form or transfer it to another organisation when the data processing takes place automatically and is based on permission or an agreement.
8.6. Contact us
You can submit a request to exercise the above rights by contacting Us at legal@cradle.bio. We aim to respond within three Weeks of receiving the request.
8.7. Complaint with the competent authorities.
You can also submit a complaint to the Dutch Data Protection Authority when you believe that Cradle violates your privacy rights.
Legal requirements
We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if We determine that such disclosure is allowed by the law or reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if We determine that this is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of public importance, to prevent or detect violations of our Terms of Service, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.
Retention of Information
10.1. Retention period
We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until your account is deleted. In addition, you can delete some items of information (e.g., profile information) without deleting your account. Following your deletion of your account, it may take up to 90 days to fully delete your personal information and system logs from our systems. Additionally, We may retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information We retain will be handled in accordance with this Privacy Policy.
10.2. Aggregation
Information connected to you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights which are commercially valuable to Cradle, such as statistics of the use of the Services.
Transfers
Your personal data will only be stored or processed by us or by third parties engaged outside the European Union (and the EEA) if this is in accordance with the applicable regulations (in particular, the GDPR) for the transfer of personal data to countries outside the European Union. This means that We will only pass on your personal data to countries outside the European Union if the European Union has decided that the third country concerned guarantees an adequate level of protection, or if other appropriate safeguards are offered, such as an adequacy decision or the use of standard contractual clauses approved by the European Commission.
Limitation of liability
Even though Cradle has taken reasonable commercial steps and efforts to prevent personal information (as defined under the (EU) General Data Privacy Regulation) from being accessed, used, intercepted or disclosed by unauthorised individuals in violation of this Privacy Policy, you should know and you acknowledge that Cradle cannot fully eliminate security risks associated with your information. Subject to the terms of any specific supply or other services agreement, you expressly acknowledge and agree that uploading, posting, providing, storing, transmitting, sharing and/or allowing access to personal information and other information through or website and/or platform and the use of the products and services on the Site, are all done at your sole risk and responsibility. You expressly acknowledge that except to the extent expressly provided for in any agreements of services applicable to you, Cradle is not liable for (i) any indirect, consequential, or punitive damages, costs, or liabilities whatsoever arising out of or resulting from your use of Our website and/or platform or (ii) any loss, disclosure or use of your personal information or other information.
Privacy Policy Information
Cradle reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Cradle makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if We make material changes, We will provide prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and, if you have created one, you should delete your account.
