Last Updated: February 26, 2021
This Policy does not apply to your use of the Finch Therapeutics main website. For information about privacy practices of the Finch Therapeutics main website, please click here.
Please read this Policy carefully before using our services.
Information We Collect
We collect personal information in different ways depending on the type of relationship that we have with you and how we interact together, so we have broken things down below to explain the types of personal information that we collect in each context.
Information You Provide to Us
- Contact details, such as your first and last name, email and mailing addresses, phone number, professional title and company name.
- Registration information, such as information that may be related to a product or an event for which you register.
- Marketing information, such as your preferences for receiving communications about our activities, events, and publications as well as details about how you engage with our communications.
- Communication with Us. We collect information when you communicate with us. The specific types of information we collect will depend on the forum in which you communicate with us. For example, if you send us an email, we will collect your email address and the content of your email.
- Stool Donation Program If you become a stool donor, or apply to our stool donation program, we may additionally ask screening questions, conduct screening tests, and conduct interviews about your health, such as:
- Screening tests of blood, stool, and mucous samples, which may be conducted on-site at Finch or at a third party testing facility;
- Demographic information about you;
- Your age, height and weight; and
- Questions about your health, health history (including family health history), current and past treatments, sexual activity, body, activities, vaccinations, travel history, and education.
Information We Automatically Collect
As with most websites, when you use our services we automatically receive and collect information about you and your device. This information includes the following:
- Device data, such as your computer’s 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, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Cookies and Analytics
By using our services, you consent to the processing of your information by us and our analytics partners in the manner and for the purposes set out above. Currently, our analytics partners include, without limitation, Google Analytics. To learn more about how Google Analytics handles your information and how they interact with our services, please visit https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. To learn more about how Google protects your data, please visit http://www.google.com/analytics/learn/privacy.html.
At the present time, our services do not respond to “Do Not Track” signals or similar mechanisms.
How We Use Your Information and Materials
Services delivery. In general, we use your personal information to:
- provide, operate and improve our services and our business;
- provide information about our products and services;
- communicate with you about our services, including by sending announcements, updates, security alerts, and support and administrative messages;
- communicate with you about events in which your participate;
- understand your needs and interests, and personalize your experience with our services and our communications; and
- provide support for our services, respond to your requests, questions and feedback.
Stool Donation Program. If you apply to or become a stool donor, we use your stool and related health information collected through the application and donation process, including your personal information (collectively, “Materials”), for the following purposes:
- Evaluate and verify your eligibility for our stool donation program;
- Research and clinical trials;
- Internal quality control;
- Product validation;
- Testing for pathogens and isolating microorganisms;
- Commercial purposes; and
- Communicate with you about our organization, programs, and donor activities.
Please note that we do not conduct human genetic testing on your stool.
Research and development. We may use your personal information and Materials for research and development purposes, including to analyze and improve our services and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve tour services and promote our business.
Marketing and promotional communications. We may send you Finch-related marketing communications, including communications about the Poop with Purpose program, as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in this Policy.
Compliance and protection. We may use your personal information and Materials to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- comply with regulatory requirements and meet regulatory oversight requirements;
- 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 and internal policies;
- enforce the terms and conditions that govern our services; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
How We Share Your Information and Materials
Let’s get this out of the way: we don’t rent or sell your personal information (any information that identifies you or is identifiable to you).
Like most companies, we share information in certain circumstances with third parties through operation of our services and our business. Below we explain when that happens.
We may share your personal information and Materials with the following parties and as otherwise described in this Policy or at the time of collection:
Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Policy.
Service providers. Companies and individuals that provide services on our behalf or help us operate our donation program, our services, or our business (such as testing facilities, hosting, information technology, payment processors, customer support, email delivery, and website analytics services).
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, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirors and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Finch or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties or the public on or through our services, that information can be seen, collected and used by others. We are not responsible for any use of such information by others.
As Directed By You and With Your Consent. Except as otherwise provided in this Policy, we share personal information with companies, organizations or individuals outside of Finch only at your direction or when we have your consent to do so.
Aggregate Information. We may de-identify or aggregate personal information or Materials so that you are not identified as an individual, and use and provide that information to third parties without restriction. We may also provide aggregate usage information to third parties (or allow third parties to collect that information from you), who may use such information to understand how often and in what ways people use our services. However, we never disclose aggregate usage or de-identified information to a third party (or allow a third party to collect such information) in a manner that would identify you as an individual person.
Stool Donation Program. If you participate in our stool donation program or screening tests, your Materials may be shared with third-party testing facilities. We may transfer stool (including samples kept in storage) or data from research involving stool and related health information of donors to third party persons or entities, such as other researchers and governmental authorities such as the U.S. Food and Drug Administration. Your identity will not be disclosed in connection with these transfers.
Choices about Your Information
Options are always nice to have, so we strive to provide you with choices with respect to your personal information. Also remember, you can opt not to disclose certain information to us – but keep in mind some information may be needed to participate in our stool donation program or to take advantage of some of our services.
Cookies and Analytics. Most browser settings let you delete and reject cookies placed by websites. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all functionality of our services and it 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 www.allaboutcookies.org.
You can prevent the use of Google Analytics relating to your use of our services by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.
You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/ and edit or opt-out your Google Display Network ads’ preferences at http://www.google.com/ads/preferences/.
Modification and Deletion of Your Information. In some situations, you may ask us to delete or modify the personal information that we have about you. To make such a request, please contact us at [email protected]. In some cases, such as if you are a stool donor, we may be required to retain, and may not be able to delete some or all of your personal information. While we aim to help you when you wish to modify or delete your personal information, we reserve the right to reject your request where we have lawful grounds to do so.
Marketing. If you opt-in, or when you apply to become a donor, we may send you newsletters and other messages, including marketing emails, SMS text messages, and other communication about our services, and to alert you to relevant advertisements and other opportunities. You can always choose to stop receiving newsletters or other communications from us by clicking the “unsubscribe” link at the bottom of any Finch or Poop with Purpose marketing message or by contacting us at [email protected]. To stop receiving SMS text marketing communications from us, you may text “STOP”, “END”, “CANCEL”, “UNSUBSCRIBE”, or “QUIT” to a text message from us. After texting STOP, END, CANCEL, UNSUBSCRIBE or QUIT to our shortcode you will receive one additional message confirming that your request has been processed. If you unsubscribe from one of our text message programs, you may continue to receive text messages from us through any other programs you have joined until you separately unsubscribe from those programs.
We are based in the United States, and our services are hosted there. If you are using our services from another country, the laws governing our collection and use of information may be different from the laws of your country. If you decide to use our services, or share your personal information with us, you are agreeing to be governed by the laws of the United States, and agree to the transfer of your personal information to the United States.
Our services are not intended for use by children under 16 years of age. If we learn that we have collected personal information through our services from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.
We employ a number of physical, technical, and administrative safeguards designed to protect the personal information and Materials that we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information or Materials.
Retention of Information and Materials
We retain personal information and Materials in accordance with applicable laws. The length of time we keep information depends on the type of information and whether we have an on-going compliance, business or legal need to retain it. Once we no longer have an on-going compliance, business or legal need to retain your personal information, we delete, aggregate, or de-identify it.
Third Party Websites and Services
Changes to this Policy
We reserve the right to modify this Policy at any time. If we make material changes to this Policy, we will notify you by updating the date of this Policy and posting it on the services. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the services. Any modifications to this Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the services after the effective date of any modified Policy indicates your acceptance of the modified Policy.
If you have any comments, questions, concerns, or suggestions about Policy, or about our privacy practices in general, please contact us at [email protected].
Finch Therapeutics Group, Inc.
200 Inner Belt Road, Suite 400
Somerville, MA 02143