Privacy Policy

Inceptive Nucleics, Inc. d/b/a Inceptive ("Inceptive," "we", "us" or "our") is a developer of foundational models for the design of novel, broadly available medicines and biotechnologies. This Privacy Policy describes how Inceptive processes personal information that we collect through our digital and online properties or services that link to this Privacy Policy (including as applicable, our website and electronic communications) and other activities described in this Privacy Policy (collectively, the "Service").

See our Notice to European Users for additional information if you are a UK or EU resident.

Our websites, products and services are designed for enterprise customers and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise and not their individual capacities.

This Privacy Policy does not apply to information that we process on behalf of our business customers while providing services to them. Our use of information that we process on behalf of our business customers is governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of our business customer, please direct your concerns to the business customer with which you have a relationship.

This Privacy Policy does not apply to our employees or independent contractors or job candidates.

Personal information we collect
Tracking Technologies
How we use your personal information
How we share your personal information
Your choices
Other sites and services
Security
International data transfers
Changes to this Privacy Policy
How to contact us
EU/UK Privacy Rights Notice

Personal information we collect

Information you provide to us.

Personal information you may provide to us includes:

Contact data, such as your first and last name, alias, signature, salutation, email address, billing and mailing addresses, and phone number.
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, or otherwise.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection.

We may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G) and general location information such as city, state or geographic area.
Communication interaction data such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Tracking technologies.

Some of the automatic collection described above is facilitated by the following technologies:

Cookies, which are small text files that websites store on user devices and that allow web servers to record users' web browsing activities and remember their submissions, preferences, credentials, and login status as they navigate a site. Cookies used on our sites include both "session cookies" that are deleted when a web browser session ends, "persistent cookies" that remain longer, "first party" cookies that we place and "third party" cookies that our service providers and other third parties place.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed, clicked or forwarded.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Operations.

We may use your personal information to:

provide and operate our web site;
enable security features our web site;
communicate with you about our products and services, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
fraud prevention and security.

Marketing and advertising.

We may collect and use your personal information for marketing and advertising purposes:

Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section.

Compliance and protection.

We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities;
protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent.

In some cases, we may specifically ask for your consent to collect, use, or share your personal information for further purposes, if those purposes are not compatible with the initial purpose for which that personal information was collected.

Cookies and similar technologies.

In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

Technical operation. To allow the technical operation of the Service, such as remembering selections as you navigate the site and remembering whether you are logged in.
Functionality. To enhance the performance and functionality of our services.
Analytics. To help us understand user activity on the Service, including the volume and demographics of users, which pages are most and least visited and how users move around the Service or interact with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout.

Data sharing in the context of corporate transactions, we may share certain personal information in the context of actual or prospective corporate transactions – for more information, see How we share your personal information, below.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Service providers.

Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, internet service providers, information technology, order fulfillment, customer support, online chat functionality providers, email delivery, marketing, consumer research and website/data analytics).

Professional advisors.

Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others.

Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Corporate transactions.

We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Inceptive, financing of Inceptive, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of Inceptive or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

In this section, we describe the choices available to you.

Opt-out of communications.

You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. It may take time for your opt-out to be effective. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies.

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.

Do Not Track.

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

Declining to provide information.

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States, have business presence in Europe, and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Individuals in Europe should read the information provided below about the transfer of personal information outside of Europe.

Changes to this Privacy Policy

The "LAST UPDATED" legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the "Last Updated" date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.

How to contact us

Email: info@inceptive.life
Website: inceptive.com
Phone: +1 (650) 507-4490

Notice to European users

General

Where this Notice to European users applies.

The information provided in this "Notice to European users" section applies only to individuals in the United Kingdom and the European Economic Area (i.e., "Europe" as defined at the top of this Privacy Policy).

Personal information.

References to "personal information" in this Privacy Policy should be understood to include a reference to "personal data" (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.

Controller.

Inceptive Nucleics, Inc. is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called 'UK GDPR' (as and where applicable, the "GDPR")). See the 'How to contact us' section above for our contact details.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a "legal basis" for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to perform a contract, we are about to enter into or have entered into with you ("Contractual Necessity").
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests"). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation ("Compliance with Law").
Where we have your specific consent to carry out the processing for the Purpose in question ("Consent").

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see 'How we use your personal information'

Purpose	Categories of personal information involved	Legal basis
Service delivery and operations	Contact data Demographic data Profile Data Communications data Transactional Data User-generated content data Relationship data Payment data Data from Third Party Services Device data	Contractual Necessity
Security	Contact data Device data Online activity data (Precise geolocation/Location) data	Compliance with Law Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service and associated IT services, systems, and networks.
Service improvement and analytics	Contact data Demographic data Profile data Device data Online activity data Precise geolocation/Location) data Communication interaction data	Legitimate Interests. We have a legitimate interest in providing you with a good service, which is personalised to you and that remembers your selections and preferences. Consent, in respect of any optional cookies used for this purpose.
Direct marketing	Contact data Demographic data Profile data Communications data Transactional data Marketing data Communication interaction data	Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Events, promotions and contests	Promotion data Contact data Demographic data Profile Data Communications data	Contractual Necessity to administer the promotions and contests in accordance with the terms or rules thereof (including communicating with you as and where necessary) In respect of promoting these promotions and contests: Legitimate Interests – we have a legitimate interest in promoting these promotions and contests, including associated publicising of our business and operations. Consent – in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given promotional communications.
Newsletter and communications	Contact data Demographic data Profile data Communications data Transactional data Marketing data Communication interaction data	Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation, including sending through our newsletter and other communications. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given communications, including our newsletter.
Service improvement and analytics	Demographic data Device data Online activity data Precise geolocation/Location) data	Consent.
Compliance and protection	Contact data Demographic data	Compliance with Law. Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
Events, promotions and contests	Any and all data types relevant in the circumstances	Legitimate interest. We and any relevant third parties have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations). However, we would always look to take steps to minimize the amount and sensitivity of any personal information shared in these contexts where possible and appropriate.
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Other info

No sensitive personal information.

We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, information related to sex life or sexual orientation, trade union membership, or information pertaining to criminal convictions) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

No Automated Decision-Making and Profiling.

As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Your rights

General.

European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights.

You may submit these requests by email to info@inceptive.life or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority.

In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK – the contact information for the UK data protection regulator is below:
The Information Commissioner's Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

It is important to note that that the US is not the subject of an 'adequacy decision' under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above).
- However, in these cases:
  - we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorise for this purpose; or
  - in limited circumstances, we may rely on an exception, or 'derogation', which permits us to transfer your personal information to such country despite the absence of an 'adequacy decision' or 'appropriate safeguards' – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at info@inceptive.life.

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