Effective Date: July 1, 2022
- in the context of our commercial activities including participation in Sight Sciences-sponsored events and provision of our products to physicians, hospitals and other customers (collectively with the Sites, our “Services”)
“Personal Information” is defined as any information relating to an identified or identifiable natural person (‘Data Subject’ or ‘Individual’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Types of Personal Information We Collect
Information You Provide to Us
We may collect, use, retain, and/or process several types of Personal Information from you, such as:
- As an end user of the Sites, when you interact with us via the “Contact Us” web forms, you may choose to provide us with certain contact Personal Information like your name, job title, email, address, phone number and other data that may be used to identify you as a specific
- If you are a healthcare professional, you may choose to provide us with information related to your practice and specialism.
- You may provide Personal Information as part of your web submissions to Sight Sciences, but we expect that you limit the Personal Information you provide to only that which is necessary and associated with the nature of your It is in our legitimate interest to offer you a means to communicate with Sight Sciences through the Sites to respond to the questions and requests you may have and provide you with information about Sight Sciences and our products you request.
- We may collect contact Personal Information where you attend a Sight Sciences event (e.g., webinar or conference) or engage with us at an event we attend or exhibit at.
- We may collect contact Personal Information from you when you interact with us directly and through our Sites regarding employment with us, including job history and qualifications, background screening information, certain financial information and other information. Please see Sight Sciences U.S. Job Applicant Privacy Notice, accessible here https://ssi.onl/ApplicantPrivacy , for more information.
- Where you otherwise engage with us in connection with our Services or provide services to Sight Sciences, we will collect contact Personal Information and information related to administering our business relationship under a contract with you or the organization you represent or work for, including transaction information and financial information.
- Our Sites are not intended for people under 18 years of age. No one under age 18 may provide any Personal Information to us or on our Sites. We do not knowingly collect Personal Information from people under 18. If you are under 18, do not use or provide any Personal Information on our Sites or through any of its features. If we learn we have collected or received Personal Information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at email@example.com.
Information We Collect From Other Sources
- Where you are a professional expert or key opinion leader (“KOL”) in your medical field, we may collect contact Personal Information and details of your practice, medical specialism and expertise where relevant to our products and services, from published sources.
- We may combine contact Personal Information you provide us with information we collect or receive about you from other publicly and commercially available sources, such as other social media platforms.
- Where you are an officer or representative of a prospective commercial partner or vendor, we may use third party diligence services to verify information about you and/or credentials.
Information We Collect Automatically When You Access or Use the Sites; Tracking
We collect certain information, associated with online identifiers when you visit our Sites. We automatically collect technical information about your online interaction and device such as the browser type and language, device operating system and Internet Protocol (IP) Address used to connect your device to the internet and from which we can derive your device country location by reference to the IP. This information is associated with information about your browser page requests as well as dates, times and duration of your use of our Sites. Collecting and tracking this type of information helps us better understand the use and effectiveness of our Sites and is in an aggregated form that is not directly associated by us with any specific named individual information. Subject to compliance with applicable law (see below regarding use of Personal Information), we may use or disclose such aggregated information for any purpose.
Our use of your Personal Information
We may use Personal Information we collect or that you provide to us for purposes, such as:
- to respond in our legitimate interest to requests, inquiries and feedback we receive from you or your company or organization;
- to verify and manage, professional status corporate risk, conflicts of interest, security, safety and compliance obligations in our legitimate interest or where required by law and where relevant to our sites, Services or services we receive;
- to take steps to enter into and administer, or enforce any contract relevant to an engagement with you or with the organization you represent or work for;
- to comply with legal and professional obligations relevant to verification, record keeping, health and safety and in assessing and where required, responding to regulatory or lawful requests;
- to analyze the use of our Sites and Services to understand in our legitimate interests (or with your consent where we use certain cookies), how we can improve our Sites and Services;
- in connection with our KOL programs, to develop in our legitimate interests, resources, encourage professional networking and build awareness, understanding and feedback on issues and treatments to which our Services relate; and
- to provide you with promotional materials about our Services relevant content and advertisements, surveys, newsletters, questionnaires, and other materials; in our legitimate interest or where required under applicable law, with your consent.
Sight Sciences Privacy Practices
We employ several technical, organizational, and physical safeguards designed to protect the information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your Personal Information.
How Long We Keep Personal Information
It is our policy and process to keep your Personal Information only for as long as it is warranted to adhere to our terms, conditions, and commitments to you, carry out legitimate interests of the business, and identify, comply to and resolve any legal or regulatory requirements.
Sharing Personal Information with Third Parties
To the extent consistent with applicable law, we will share your Personal Information in the following circumstances:
- Third Party Service Providers. Third party service providers work on behalf of Sight Sciences and help us operate our Sites, Services or our business operations (including IT, hosting, software support, relationship management, data management, verification services, email delivery, marketing, web services, event management services). When third parties process or require access to Personal Information, we ascertain that the third party is obligated to provide at least the same level of privacy protection as we hold ourselves to. Sight Sciences maintains contracts with these third parties that restrict their access, use, and disclosure of Personal Information in compliance with the laws and regulations that apply. Our third parties are required to notify us if they determine they can no longer meet the level of data protection expected by Sight Sciences, and we monitor for compliance to our data protection terms depending on the nature of the services being provided.
- Advisors. We may share Personal Information with our auditors, legal advisors and other professional advisors.
- Our stockholders, investors, finance providers and business partners. We may provide Personal Information in order to provide aggregated reporting data and to otherwise manage and fulfil our agreements with and obligations to our stockholders, investors, finance providers and other business partners.
- Reorganization of Sight Sciences. In the event we sell or transfer all or a portion of a business or assets to a third party, such as in connection with a merger or in the event of a bankruptcy reorganization or liquidation.
- With Your Consent. We may share your information when you or your company or organization consent to or request such sharing. This includes, but is not limited to, when you provide information through the “Find a Physician” function on our Websites, we may disclose the information to our subsidiaries, affiliates, or to health care providers in your area in order to put you in touch with clinicians.
International Transfers of Personal Information
We are a US company and the data that we collect from you from our Sites or in connection with our Services will be stored in the USA which (if you are located in another country) may not have equivalent Data Protection Laws to those of your home jurisdiction.
If you would like or more detail about how we protect your Personal Information when we transfer it, please contact us using the information found below.
Links to Third-Party Websites
Our Sites may contain links or references to third-party owned or operated websites or online services. Sight Sciences is not responsible for the collection of personal information or the security or privacy of any such third-party sites or services. Likewise, Sight Sciences is not responsible for the collection, usage, and disclosure policies and practices (including the data security practices) of any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any information you disclose to such other organizations through or in connection with our social media pages, any mobile sites, applications, widgets, and other mobile interactive features. We encourage you to review the privacy statements posted on the websites you visit.
Important Information for California Residents
This section describes the rights of California residents in respect to their Personal Information. For purposes of this section, “Personal Information” has the meaning given in California Assembly Bill 375 (the California Consumer Privacy Act of 2018 or “CCPA”) but does not include information exempted from the scope of the CCPA.
Your California Privacy Rights.
As a California resident, the CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Here is a summary of how we currently collect, use and share personal information, and how we have collected, used and shared the information in the preceding 12 months:
|Categories of Information||Descriptions||Method of Collection||Business or Commercial Purposes|
|Identifiers||This category includes a real name, alias, phone number, postal address, email address, Internet Protocol Address, Account Name, or other similar identifiers that can identify a user, family or device||This information is not collected unless voluntarily provided by you through the Sites or through our provision of the Services.||Providing information or services you requested to respond in our legitimate interest to requests, inquiries and feedback we receive from you or your company or organization.|
|Commercial Information||Records of products or services purchased, obtained, or considered, or other purchasing or consuming history||This information is not collected unless voluntarily provided by you through the Sites or through our provision of the Services.||Providing information or services you requested to respond in our legitimate interest to requests, inquiries and feedback we receive from you or your company or organization.|
|Customer Records (California Customer Records Statute Cal. Civ. Code § 1798.80(e)).||This category includes 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.||This information is not collected unless voluntarily provided by you through the Sites or through our provision of the Services.||Communicating with you for any purpose outlined in the “Our use of your Personal Information” Above.|
|Internet Activity||Internet Protocol Address, Other Device specific information (i.e. OS, Device Type), General Location data, Web Browsing Information||The Sites collect user browsing history, search history, and information on your interactions with the Sites. This information may be collected from observing your actions on our Sites.||To analyze the use of our Sites and Services to understand in our legitimate interests (or with your consent where we use certain cookies), how we can improve our Sites and Services.|
|Geolocation Data||Physical location||This information may be collected from observing your actions on our Sites or if this information is voluntarily provided by you through the Sites.||To analyze the use of our Sites and Services to understand in our legitimate interests (or with your consent where we use certain cookies), how we can improve our Sites and Services.|
|Professional or Employment Related Information||This category includes information like contact information, background check information, educational history, current or past job history and qualifications or performance evaluations, equal opportunity, and equal opportunity information.||This information is not collected unless voluntarily provided by you through the Sites.||Please see Sight Sciences U.S. Job Applicant Privacy Notice, accessible here https://ssi.onl/ApplicantPrivacy , for more information.|
|Protected classification characteristics under California or federal law||This category includes characteristics of protected classifications under California or federal law like race, national origin, religion, gender or sexual orientation.||This information is not collected unless voluntarily provided by you through the Sites.||Please see Sight Sciences U.S. Job Applicant Privacy Notice, accessible here https://ssi.onl/ApplicantPrivacy , for more information.|
California residents are entitled once a year, free of charge, to request and obtain certain information regarding Sight Sciences’ disclosure of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year.
You may request that we limit or delete the Personal Information that we have collected, use, and/or retain by contacting the Legal Department (see “How to Contact Us” below).
You are entitled to exercise the rights described above free from discriminatory treatment from Sight Sciences for exercising any of your rights under the CCPA, including any discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Services.
How to Exercise Your Rights
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. We reserve the right to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s validate government- issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Important Information for Individuals Outside the US
This section describes the rights of European residents in respect to their Personal Data. For purposes of this section, “Personal Data” has the meaning given in the General Data Protection Regulation (Regulation (EU) 2016/679), the UK’s Data Protection Act 2018, the German Act on Data Protection, and other applicable law based on your locality but does not include information exempted from the scope of the referenced laws.
Your European Privacy Rights
As a European resident, you have the rights listed below. However, these rights are not absolute, and in
certain cases we may decline your request as permitted by law.
- Provide consent or to withdraw We may seek to rely on your consent in order to process certain Personal Information. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
- Access: You may have the right to access the Personal Information that we hold about
- Rectification: You may have the right to require us to correct any inaccurate or incomplete Personal Information.
- Erasure: In certain circumstances, you may have the right to the erasure of Personal Information that we hold about you (for example if Personal Information is no longer necessary for the purposes for which it was originally collected).
- Data portability: You may have the right to receive the Personal Information concerning you in a structured, commonly used, and machine-readable format that can be shared with another organization. The right of data portability also allows you the opportunity to have Sight Sciences transmit that data to another organization directly where technically
- Object to processing: You may have the right to request that Sight Sciences stop processing your Personal Information and/or to stop sending you marketing
- Restrict processing: You may have the right to request that we restrict processing of your Personal Information in certain circumstances (for example, where you believe that the Personal Information we hold about you is not accurate or lawfully held).
How to Exercise Your Rights
You may exercise your European privacy rights by submitting a request through Sight Sciences’ online request form found at http://ssi.onl/PrivacyRightRequest.
We prefer to resolve your questions, complaints, and requests about how we handle Personal Information directly; however, if your request or concern is not satisfactorily resolved by us, you may approach the relevant data protection authority
How to Contact Us
SIGHT SCIENCES, INC.
Attn: Legal Department
4040 Campbell Avenue, Suite 100
Menlo Park, CA 924025
Telephone: (877) 266-1144
Fax: (650) 352-4401