Policies and Procedures

Guild Associates Privacy Policy

This Privacy Policy describes the types of personal data that Guild Associates, Inc., Guild Biosciences, and their affiliated entities (collectively, “Guild,” “we,” “us,” or “our”) may collect from or about you when you visit our websites, microsites, or mobile sites that expressly adopt, display or link to this Privacy Policy (collectively, the “Website), use Guild’s services, communicate with us, or visit the official social media pages we operate on Facebook, LinkedIn, and other social media platforms (“Social Media Pages”).  This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your personal data.

Information We Collect

We may collect the following types of information about you:

• Device Information: When you visit our Website, interact with our Social Media Pages, or open our emails, we automatically learn about your browser, device type, IP address, internet service provider, and other technical information about your device.
• Location Information: We may learn your geographic location through various technologies, including your IP address or other device information, which may depend on your device’s settings for location services.
• Website Interactions: We collect information about your interactions with our Website. This information could include personal data, depending on what information you provide.
• Contact Information: We may collect your contact information, such as your first and last name, email address, phone number, and physical address.
• Job Applications: If you apply for employment, we have access to the content you provide such as your resume, cover letter, and any information contained therein.
• Payment Information: Your payment details may be collected in connection with an order.
• Call and Email Records: If you call or email us, we may keep records of those conversations.
• Social Media Information: We receive aggregated information about people who visit and interact with our Social Media Pages. “Aggregated” means information that doesn’t include personal information associated with identified natural persons.
• Content You Submit: We collect any content you submit to our Website, Social Media Pages, or to us in person.

How We Collect Your Information

We may collect the information described above directly from you, from third parties we partner with, or through cookies or other automated means. These sources may include:

• You: We collect information directly from you, whenever you: visit our Website; contact us with questions or comments; upload content to our Website or Social Media Pages; make a purchase; provide information in connection with a job application; or fill out any forms on our Website or Social Media Pages.
• Your device or browser: Certain information is automatically collected from your device or browser when you visit our Website, interact with our Social Media Pages or online advertising, or open our emails.
• Third parties: We work with third parties who provide services to us, like analytics or advertising companies. These third parties share information they have collected with us. Your information may also be collected and processed by third parties, such as payment providers, who will process your information independently in accordance with their own privacy notices.
• Cookies: We use cookies (small data files stored on your device or browser) and other similar technologies to automatically collect information when you visit our Website or interact with our emails. Through the use of cookies, we may link information about your interactions with our Website or emails over time. Any information collected by us or by third parties through the use of cookies or similar technologies may be linked with other information we collect about you.

How We Use Your Information

We may use your information for the following purposes:

• Providing Products and Services: Providing our products and services to you, promoting our products and services, submitting proposals, improving our products and services, communicating with you about our products and services, negotiating contracts, sending invoices, providing customer support, managing our relationship with you, and managing payments.
• Online Advertising: Presenting advertising online and via email, or other communication channels, including through partnerships with social media platforms and internet search engines.
• Communications: Communicating with you, including responding to your requests, updating you about our terms, policies and/or technical changes, asking for feedback through surveys or other messages, or sending you information that we think may be of interest to you.
• Website Experience: Analyzing your online activity with us, serving content on our Website and Social Media Pages, developing our services and improving the Website to ensure that content is presented in the most effective manner for you.
• Performing a Contract: Processing your information in connection with pre-contract activities and discussions with you, or performing a contract that we have with you or your business.
• Recruitment: Recruiting and hiring, including, but not limited to, verifying your eligibility for employment and assessing your suitability for any position for which you may apply at Guild.
• Security: Protecting Guild, our customers and our Website users from fraud, security threats, and other illegal or harmful activity.
• Legal Obligations: Complying with legal and regulatory requirements and responding to requests from courts or other government bodies.
• Other Legitimate Interests: Processing your information for any of our other legitimate interests not described above.

How We Share Information with Service Providers and Third Parties and For What Purposes

We may share your information in the following situations:

• With service providers: We partner with third parties to assist with many aspects of our business, including fulfilling orders, collecting applications for employment, and helping us communicate with you. These third parties may provide services related to any of the purposes described in How We Use Your Information and we may share with them any types of information described in Information We Collect.  We may also receive information collected by these third parties and combine it with the information we have collected. Your information may also be collected and processed by third parties who will process your information independently in accordance with their own privacy notices.
• For business transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.
• With marketing providers: We partner with third parties to assist with the advertising and marketing of our business. We may share with them the types of information described in Information We Collect. We may also receive information collected by these third parties and combine it with the information we have collected.
• For legal compliance: We will disclose information about you, including to government bodies or law enforcement agencies, when we believe it to be necessary for compliance with the law or to protect our Website, the users of our Website, or the public.
• With your consent: We may disclose your information for any other purpose with your consent.

Retention of Your Information

Guild will retain your information for as long as is necessary to fulfil the purpose for which your information was collected and in accordance with our internal retention procedures, or as otherwise necessary to satisfy our legal obligations, resolve disputes, and enforce our agreements and policies.

In some circumstances we may anonymize your information for research or statistical purposes in which case we may use such anonymized information indefinitely.

Third Party Links

For your convenience, we may enable you to navigate to third-party sites through links on our Website.  We do not endorse these third-party sites, do not have any affiliation with these third-party sites, and we do not control and are not responsible for their Internet and web practices.  Whether the third-party content appears within our Website environment (like a map frame), or you leave our Website for another website to view it, the terms, conditions, and privacy policies of those other websites govern your online experience.  Please review their separate terms of service and privacy policies if you have any questions about their practices.

Your Privacy Choices

You can control the information we collect and use in the following ways:

• Location Information: You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Website from accessing your location information. Note that some services may not be available if you disable location-based services.
• Marketing Emails: You may opt-out of our marketing emails by following the instructions listed in any email communications that you receive or by contacting us using the contact details provided under Contact Us, below.
• Social Media: This Privacy Policy does not cover the privacy and security practices of social media platforms on which we have Social Media Pages. Please review the terms, policies, and settings of those social media platforms if you have questions about how they collect and use your data.
• Online Advertising: For information about opting out of third party advertising, visit: NAI Opt-Out or DAA. You will leave this Website for a separately managed online site where you can specify your preferences. You can also click on the icon that may appear on some of our advertising served through this technology. We may use more than one third party company for placing this advertising, which would require you to opt out of each company.
• Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.  Depending on your location, we may utilize Google Analytics.  You can opt out of Google Analytics across all websites you use.  To do so, visit this website.  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Children’s Privacy

Our Website and Social Media Pages are not intended for children under the age of 16. No one under 16 should share any personal data with us. We do not knowingly collect any personal data from children under 16. To request deletion of personal data relating to a child under 16, please notify us by sending an email to WebsitePrivacy@guildassociates.com.

Security

We employ physical, technical, and administrative procedures to safeguard the personal data we collect online.  While we use these security measures on our Website, you should be aware that 100% security is not always possible.

Changes to this Privacy Policy

We may make changes to this Privacy Policy at any time to take into account new or changing circumstances, so please review it periodically. Material changes in our Privacy Policy will be communicated as Guild determines appropriate, including, but not limited to, by posting on our Website or communicating by email.  We will update the effective date at the bottom of the page at the time a change is made.

U.S. State Privacy Rights

Certain U.S. states afford residents rights with respect to their Personal Data.  The rights described herein are subject to exemptions under applicable law.  For purposes of this section, the term “Personal Data” includes both “Personal Information” and “Personal Data” as defined by applicable law.

If your Personal Data is subject to a consumer privacy law in your state, you may have certain rights with regard to that information.  You may have the right to:

• Know, access, and confirm your Personal Data.
• Delete the Personal Data we have about you, subject to exceptions under applicable law.
• Correct inaccuracies in your Personal Data.
• Obtain your Personal Data in a portable and readily usable format.
• Opt-out of the use or processing of your Personal Data for profiling or targeted advertising.
• Opt-out of the sale or sharing of your Personal Data.

Under certain state laws, you may also have the right not to receive discriminatory treatment for the exercise of any of these privacy rights.  We will not discriminate against you because you have exercised any of your rights.

Certain state laws may also provide you the right to appeal our decisions regarding your rights requests if we do not respond to your requests or do not take action regarding your requests.  Additionally, if you are a resident of the state of California, you may have a right to pursue legal action for improper handling of your Personal Data.

How to Submit a Request

If you wish to exercise one of the rights listed above, and are a resident of a state that provides such privacy rights, you may submit a request by emailing WebsitePrivacy@guildassociates.com, by calling us toll-free at 855-895-2170, or by using the form at the bottom of this page. We will provide your Personal Data to you in writing in a readily usable format.  If you choose to submit your request via email, you must include “Privacy Rights Request” in the subject line and clearly provide us with the following information: what type of request you are making, your full name, email address, and valid physical address.  You may only make one request per email.

We are required to provide access to Personal Data or delete Personal Data only in response to verifiable consumer requests. We will compare the information you provide to us in your request to any information we may have in our possession in order to verify your request. You may be asked to provide us with information such as your home address, email address, and telephone number. We may also contact you to request additional information in relation to your request. Please promptly respond to any follow-up inquiries so that we may verify your identity. If you request that we provide you with specific pieces of information about you, we may apply heightened verification standards than what we would apply to other types of requests. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Data is not disclosed to any person who does not have the right to receive it. The information collected through this process will be used for verification purposes only.

Authorized Agent

Please note that you may authorize an agent to exercise any of these rights on your behalf by emailing WebsitePrivacy@guildassociates.com, by calling us toll-free at 855-895-2170, or by using the form at the bottom of this page. If you use an agent, we will take measures to verify your agent’s authorization similar to the verification described above for fulfilling any access or deletion requests. We may require more information to ensure proper verification of you and your agent’s identity and authorization.

Categories of Personal Data Collected and Disclosed for a Business Purpose

We collect and disclose the following categories of Personal Data.  Note that the specific pieces of Personal Data we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed.

• Identifiers – such as your name, address, email address, online identifiers, or other similar identifiers.
• Records Information – such as your name, signature, address, and telephone number.
• Internet or other electronic network activity information– such as your IP address, device identifiers, and information regarding interactions with our services or advertisements.
• Professional or employment-related information
• Inferences – used to create a profile reflecting your preferences, characteristics, and behavior.

We may also collect Personal Data about you that does not directly fit within one of the categories listed above, which information is described in Information We Collect.

We share Personal Data about you with service providers and third parties for business purposes, such as operational purposes and other purposes related to providing you with the products and services you seek from us.  For more information about the business purposes for which we disclose Personal Data, see How We Use Your Information.

“Do Not Sell” Rights; Sharing for Cross-Context Behavioral Advertising, Profiling, or Targeted Advertising

We do not sell Personal Data or share Personal Data about you for purposes of cross-context behavioral advertising, profiling, or targeted advertising.

We may disclose your Personal Data for the following purposes, which are not a sale: (i) for reasons mentioned above; (ii) if you direct us to share Personal Data; (iii) to comply with your requests under applicable law; and (iv) as otherwise required or permitted by applicable law.

Deletion Rights

You may request that we delete your Personal Data that we have collected directly from you.  Under applicable law, we may decline to delete your Personal Data under certain circumstances, for example, if we need the Personal Data to complete transactions or provide products or services you have requested or that are reasonably anticipated, for security purposes, for internal business purposes (including maintaining business records), to comply with law, or to exercise or defend legal claims.  Note also that we are not required to delete your Personal Data that we did not collect directly from you.  We require a reasonable or high degree of certainty that the requester is the consumer for which a deletion request is applicable, depending on the sensitivity of the Personal Data.  (See How to Submit a Request, above).

Additional California Privacy Rights

We do not share Personal Data as defined by California Civil Code Section 1798.83 (“Shine the Light Law”) with third parties for their direct marketing purposes absent your consent.  If you are a California resident, you may request information about our compliance with the Shine the Light Law by emailing us at WebsitePrivacy@guildassociates.com or sending a letter to Guild Associates, Inc., 5750 Shier-Rings Road, Dublin, OH  43016, (Attention: Privacy Inquiry).  Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.  Please note that we are only required to respond to one request per individual each year, and we are not required to respond to requests made by means other than through this email or mail address.

Sensitive Personal Information and Sensitive Data

We will not process your Sensitive Personal Information or Sensitive Data (as those terms are defined under applicable privacy law) without your prior consent.

Contact Us

If you have any questions, comments, or concerns about this Privacy Policy, please contact us by emailing WebsitePrivacy@guildassociates.com. When writing to us, please make sure to include your name and email address or telephone number so that we can contact you.

Effective Date (last updated):  February 22, 2024