Last updated: September 6, 2022

The Privacy Policy describes how Rockley Photonics (“Rockley,” “we” and “us”) collects, uses, protects, and discloses information when you visit or use our website, rockleyphotonics.com or mobile applications (each a “Site” and collectively “Sites”), contact our customer service team, engage with us on social media or otherwise interact with us, purchase our products or participate in our research studies or clinical trials. This Privacy Policy applies to all users of the website. By using the website, you are consenting to this Privacy Policy. Please read it carefully.

Personal Information We Collect

Listed below are details about the categories of information we collect:

• Contact Information: name, email address, mailing address, and telephone number
• Demographic information: We may collect information like your gender and age. We may also collect your zip/postal code.
• Financial Information: tax identification number, financial or bank account information, tax-related information, and wire instructions
• Identifiers: IP address, user name, account number, password and other security information for authentication and access
• Geolocation Data: the general region or area from which you access our site
• Usage Data: data concerning your Internet or other electronic activity including browsing and click history, device types, operating system, browser settings, IP address, language settings, and Site use data including information about how you navigate the Site, other websites, and the Internet
• Audio/Visual Data: audio, electronic, photographic, visual or similar data including videos, photographs, or audio recordings
• Commercial Information: records of products or services purchased, obtained or considered, or other purchasing or consuming histories
• Health Information: health history, medications, treatment history, name, medical record information, temperature, weight, blood pressure, and heart rate
• Applicant Information: If you apply for a job, we collect information about you, your prior education and work history and your skills and qualifications for the position. We may ask about your salary expectations and how you learned of the position. We may also ask you for contact information for references.
• Investor Information: If you invest with us or are a broker whose clients invest with us, we may collect your name, email address, telephone number, mailing address, and share ownership data.
• Inferences: We may use information from the categories described above in order to create a profile about you, to reflect your preferences, characters, behavior, and attitude.

Business Purposes for Collecting Personal Information

We use your personal information for the following purposes:

• Transactional Purposes: We use your contact information, demographic information, financial information, identifiers, commercial information, health information, investor information and inferences to:
  • Provide you with the requested products or services
  • Provide a quote for our products or services
  • Fulfill your order
  • Process payments
  • Qualify you for participation in and conduct our research studies and clinical trials
  • Send confirmations and shipping or transit information and track your shipment
  • Communicate with you
  • Respond to customer service requests and inquiries; and
  • Administer an online account

• Employment Purposes: We use your contact information, demographic information, audio/visual data, applicant information, and inferences when you apply for a job with us.
• Analytical Purposes: We use your identifiers, usage data, geolocation data, commercial information, and inferences to analyze preferences, trends, and statistics.
• Marketing and Promotional Purposes: We use your contact information, identifiers, commercial information, usage data, geolocation data, audio/visual data, and inferences to improve our marketing efforts, create social media posts or advertisements, and provide you with information about us, including personalized marketing communications.
• Maintenance and Improvement of the Sites: We use your contact information, commercial information, identifiers, employment information, geolocation data, audio/visual data, and usage data to improve our Sites, provide and maintain functionality on our Sites, and help us diagnose technical and service problems and administer our Sites.
• Develop and Improve Our Products and Services: We use your contact information, demographic information, financial information, identifiers, geolocation data, usage data, audio/visual data, commercial information, health information, applicant information, and inferences to help us develop new products and services and to improve and analyze our existing products and service offerings.
• Investor Relations: We use your contact information, identifiers, investor information, and inferences to communicate with you regarding your purchase or ownership of stock, our financial performance, and to provide legally-required disclosures and information.
• Security and Fraud Prevention: We use your contact information, identifiers, commercial information, financial information, geolocation data, usage data, audio/visual data, and inferences to protect our Sites, products, and services; to protect us, our affiliated companies, our employee, our carriers and others; and to prevent fraud, theft and misconduct.
• Legal: We use your contact information, identifiers, financial information, employment information, geolocation data, usage data, audio/visual data, and inferences to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.

Methods of Collecting Information

We collect information in a variety of ways:

• Directly from you: We collect contact information, demographic information, financial information, identifiers, commercial information, health information, applicant information, and investor information that you provide directly to us.
• When you visit our offices or research facilities: When you visit our offices or research facilities, we also collect contact information, health information and audio/visual data.
• Automatically: When you access our Sites, we collect identifiers, geolocation data, and usage data using tools like browser cookies.
• From third parties: We may collect contact information, identifiers, commercial information, health information, applicant information, investor information, audio/visual data, and inferences from third parties, including investor relations companies, research institutions, service providers, and public authorities.
• From social media platforms and networks: We may collect contact information, identifiers, geolocation data, usage data, commercial information, and audio/visual data from social media platforms and networks that you use in connection with our websites or mobile applications, or that share or allow you to share information with us, such as Facebook, LinkedIn, Twitter, and Instagram.

We Combine Information

We combine information we obtain from different sources with publicly available information, including to create inferences about you. For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third-party sites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.

How We Share Information With Others

We will share personal information in the following circumstances or as otherwise described in this Privacy Policy:

• Service Providers: We may share personal information with vendors and service providers who support the operation of the Services, the Sites, and our business and who need access to such information to carry out their work for us (including, for example, web hosting, analytics, payment processing, order fulfillment, email delivery, marketing, insurance, transportation, storage and warehouse services, shipping, background check, credit verification, and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf.
• Affiliates: We may share personal information with and among our parent company, subsidiaries, affiliates, or their successors or assigns.
• Research Institutions: We may share personal information with hospitals, universities, or other research institutions.
• Marketing/Analytics/Advertising Partners: We may share personal information with third-party marketing, analytics, or advertising partners, including social media platforms and networks, for commercial purposes such as sending you marketing emails and advertisements.
• Professional Advisors: We may share information with professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
• Government Entities: We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; corporate registries; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process, or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights, or the rights of others, including by responding to claims asserted against us.
• Corporate Transaction Recipients: We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer, or disposition of all or any portion of our ownership interest, business, or operations.
• With Your Consent or At Your Direction: We may share information with third parties whenever you consent to or direct such sharing.
• Other Reasons: We may share information for other reasons we may describe to you.

How Long We Keep Personal Information

We will retain and use your information for as long as your account is active, as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer use your information to provide you services or products, please contact us at privacy@rockleyphotonics.com.

Cookies, Analytics, and Other Tracking Technology

Cookies and Tracking Technology
We want you to be aware that certain online tools exist to help us serve and recognize you when you visit our Sites. We receive and store certain types of information when you visit our Sites. When you access the Sites, we (including companies we work with) may place small data files on your computer or other device. These data files may be web beacons, cookies, clear gifs, pixel tags, e-tags, flash cookies, log files, or other local storage provided by your browser or associated applications. These tracking technologies, which are often referred to collectively as cookies, allow us to understand how users navigate to and around our Sites, view different pages, access content and request Services. We may use them, for example, to keep track of your preferences and profile information and collect general usage and volume statistical information. If you want to remove or block cookies, you may be able to update your browser settings.You can also find instructions on how to manage cookies on different types of web browsers at www.allaboutcookies.org. To change your preferences regarding cookies, please click on the banner at the bottom of the page.

Do Not Track Signals
Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit allaboutdnt.com.

Third-party Analytics and Advertising
We allow others to provide analytics services and serve advertisements on our behalf across the Internet and in mobile applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Sites and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked and conversion information. We use this information to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your online activity.

Google Analytics
We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit www.google.com/policies/privacy/partners. If you would like to opt out, Google provides a an opt-out tool which is available at tools.google.com/dlpage/gaoptout.

Links to Other Websites

Our Sites may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

Security

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative, and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.

This Website is Not Intended for Children

We do not knowingly collect or store any personal information from anyone under the age of 13. If we become aware that we have collected or stored personal information from an individual under age 13, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to privacy@rockleyphotonics.com.

Marketing Communications

You can opt out of marketing or advertising emails and newsletters by using the “unsubscribe” link or mechanism noted in communications you receive from us. You may also request to opt out of marketing or advertising emails by contacting us through one of the methods specified in the Contact Us section of this Privacy Statement. Once we process your request, we will cease using the information for such purposes at no charge to you. If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us where permitted by law.

Processing in the United States

We are based in the United States. If you are using the Sites from outside the United States, please be aware that information we obtain about you will be processed in the United States or in other jurisdictions. By using the Sites or Services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own, including the United States, as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other countries may be different from the laws in your country of residence. The United States may not afford the same level of protection as laws in your own country. Information we transfer from the European Economic Area, the United Kingdom, or Switzerland to the United States will be subject to appropriate safeguards under applicable law. Those safeguards may include standard data protection clauses approved by the European Commission/ICO and available on their website.

State Specific Provisions

California
Shine The Light: If you are a California resident, this section applies to you. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at privacy@rockleyphotonics.com, andinclude “CA Shine the Light” in the subject line of your email.

California Consumer Privacy Act (CCPA) Disclosures:

Categories and sources of personal information we collect: In the preceding 12 months, we have collected the following categories of personal information: contact information, demographic information, financial information, identifiers, geolocation data, usage data, audio/visual data, commercial information, health information, applicant information, investor information, and inferences. For details about precise data points we collect and the categories of sources of such collection, please see the sections above titled Personal Information We Collect and Methods of Collecting Information.

Purposes for which we use personal information: We collect personal information for the business and commercial purposes described in the section above titled Business Purposes for Collecting Personal Information. 

Disclosure for a business purpose: In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients: 

For a more expansive description of the categories of recipients, please see the How We Share Personal Information section above.

Your Rights Under the CCPA
Subject to certain exceptions, the CCPA affords California consumers the following rights:

1. The Right to Right to Know About Personal Information Collected, Disclosed, or Sold
You have a right to request what personal information we have collected, used, disclosed, and sold about you in the preceding 12 months. You can also request the specific pieces of personal information we have collected about you. You can also request the following categories of information:

• The categories of personal information we have collected about you
• The categories of sources from which the personal information was collected
• The business or commercial purpose for collecting or selling the personal information
• The categories of third parties with whom we shared personal information

2. Right to Request Deletion of Personal Information
You can also request that we delete your personal information. We may not delete all of your personal information if one of the exceptions to the CCPA applies. Please note that if we delete your personal information, the Services provided may not maintain the same functionality. For example, your previous opt out requests will not be saved and saved preferences and information will no longer be available.

3. Right to Opt-Out of Sale of Information
You have a right to opt-out of the sale of your personal information. The CCPA defines a “sale” as disclosing or making available to a third party personal information in exchange for monetary or other valuable consideration.We do not sell personal information.

4. Right to Not Be Discriminated Against
You have a right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.

Exercising Your Rights Under the CCPA
To exercise any of your CCPA rights, please email us at privacy@rockleyphotonics.com or call us at (888) 730-6075. You must use “CCPA Request” in the subject line of your email. For all requests, you must provide us with your name, email address, phone number, and mailing address. Failure to provide all of the foregoing information will prevent us from processing your request.

Further, in order to verify your identity, we will provide a verification form to you at your email address. Please be aware that you must complete the verification form and submit it to us in order for us to match that information to the information we have in our systems and process your request.

Additionally, some requests may be subject to additional identity verification procedure. In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us at privacy@rockleyphotonics.com.

Other Consumer Rights Information: Under California Civil Code Section 1789.3, we are required to provide California residents with the following information:

• Unless otherwise expressly stated, this Site is provided without charge.
• To file a complaint regarding this Site or to receive further information regarding use of this website, please contact us via email at privacy@rockleyphotonics.com. You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California’s Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at (916) 445-1254 or (800) 952-5210.

Country/Region Specific Provisions

European Economic Area (EEA), the United Kingdom, and Switzerland
For residents of the European Economic Area (EEA), the United Kingdom, and Switzerland, the following additional privacy elements apply to you. We are committed to protecting your privacy and will only use your personal information in accordance with applicable data protection legislation.

Lawful Basis for Processing Personal Information: The lawful basis for our collection and use of your personal information described in this Statement is that the processing is (i) necessary for our legitimate interests in carrying out our business, provided those interests are not outweighed by your rights and interests; (ii) necessary to perform a contract with you; (iii) necessary to comply with a legal obligation; or (iv) based, when necessary, on your consent.

Disclosure and Cross-Border Transfer: We are a global company, and your personal information will be shared among us and transferred outside of your country of residence. Personal information that is transferred outside of the European Economic Area, Switzerland, or the United Kingdom is conducted in accordance with compliant transfer arrangements such as data transfer agreements that contain standard contractual clauses adopted by the European Commission that provide safeguards for such transfers.

Special Categories of Data: We request that you do not send to us (unless we specifically request) any Special Categories of Data, which is defined under relevant data protection laws as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric characteristics, health, or sexual orientation.

Segmentation and Automated Decision Making: We do not use segmentation or automated decision-making without human intervention, including profiling.

Your Rights Over Your Personal Information: You have the right to request that we:

• confirm whether we are processing your personal information;
• provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format;
• update or correct your personal information when it is inaccurate or incomplete;
• cancel or delete your personal information in certain circumstances;
• limit the processing of or stop processing your personal information in certain circumstances;
• or revoke consent previously granted to the extent permitted by law.

To exercise any of these rights, please contact our Data Protection Officer at privacy@rockleyphotonics.com.

You can also write to us at:

Rockley Photonics
Attn: Data Protection Officer
3rd Floor 1Ashley Road
Altrincham
Cheshire
United Kingdom
WA14 2DT

You must use “GDPR Request” in the subject line of your email or letter. For all requests, you must provide us with your name, email address, phone number, and mailing address. Failure to provide all of the foregoing information will prevent us from processing your request.

Further, in order to verify your identity, we will provide a verification form to you at your email address. Please be aware that you must complete the verification form and submit it to us in order for us to match that information to the information we have in our systems and process your request.

Filing a Complaint: If you are in the EU, Switzerland, or UK, you may lodge a complaint concerning our data processing activities by contacting your local data protection authority. Contact information may be found here. We encourage interested persons to raise any concerns using the contact information provided, and we will investigate and attempt to resolve any matters related to the use and disclosure of your personal information.

Contact Us

If you have any questions about this Policy or our data practices, please email our Data Protection Officer at privacy@rockleyphotonics.com.

You can also write to us at:

Rockley Photonics
Attn: Data Protection Officer
3rd Floor 1Ashley Road
Altrincham
Cheshire
United Kingdom
WA14 2DT

Updates

From time to time we may change our privacy policies. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on the website where this appears. Please check our website periodically for updates.