Rockley Photonics Holdings Limited Privacy Policy

This Privacy Policy describes the privacy practices of Rockley Photonics Holdings Limited. (“Rockley,” “we,” “us,” “our”). Please read this Privacy Policy (“Policy”) to learn how we collect, use, and share or otherwise process information relating to individuals (“Personal Data”) that we obtain through or in connection with your use of www.rockleyphotonics.com (“Site”) and your rights and choices regarding our process of your Personal Data. By using the Site and submitting information, you agree that we may use and disclose your information according to the terms of this Policy.

“Personal Data” is information (including “personal information” as that term may be defined) that, directly or indirectly, identifies you or another individual and which may include: name, title, company name, expertise, postal address, telephone number, email address, browser and device information (including IP Address), and information collected through cookies and other similar technologies. If you submit any Personal Data relating to other people to us or to our service providers in connection with the Site, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.

“Other Information” or “Other Data” is any information or data that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymized and aggregated. We use this information to facilitate our operation of the Site and for other purposes described below.

For the purposes of the UK Data Protection Act 2018 (the “DPA”) and the EU General Data Protection Regulation 2016/679 (the “GDPR”) and other laws globally, Rockley is the “controller” and is responsible for deciding how Personal Data is used, collected, and processed, unless expressly specified otherwise. We are a limited liability company registered in England and Wales (Number: 8683015), with registered offices at 1 Ashley Road, Altrincham, Cheshire WA14 2DT United Kingdom. By using or accessing the Site, or by providing Personal Data to us on or through the Site, you acknowledge that you have read and understood the policies and procedures described in this Statement. This Privacy Statement does not apply to the practices of third parties that Rockley does not own or control, or to individuals that Rockley does not employ or manage.

If you have any questions or concerns about this Policy, please email us at contact@rockleyphotonics.com.

Information Collected and How It Is Used

We automatically collect information when you visit the Site including your device’s IP address, and statistics about how you use the Site. We use this information for the operation of the Site and to maintain quality of the service, and to provide general statistics regarding use of the Site including:

  • To measure the use of our Site, including number of visits, average time spent on a Site, pages viewed, page interaction information (such as scrolling, clicks, and mouse-overs), etc., and to improve the content we offer;
  • To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
  • As part of our efforts to keep the Site safe and secure.

We collect Personal Data that you voluntarily submit when visiting the Site including job application information, your employment and educational history, location, immigration status, references, and other related information if you choose to submit it through our Careers page.

We use the collected information for our general commercial purposes such as to improve our Site, manage our staffing and human resources administration, grow our business and to respond to your inquiries or to provide information on products or services to you.

Where your consent is not mandatory, we may process Personal Data on the following lawful bases:

  • For the performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract.
  • As necessary in certain legitimate interests (including our business interests), provided such interests are not overridden by your interests or fundamental rights.

We will process Personal Data for the following purposes as is necessary for the performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract:

  • To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
  • To assist you in completing a transaction or order;
  • To prepare and process invoices;
  • To respond to queries or requests and to provide the services and associated support;
  • To provide customer relationship management;
  • To create and manage our accounts;
  • To notify you about changes to our services;
  • For those submitting information on our Careers page, to assess your suitability for the position for which you are applying, to contact you in relation to your application, to manage and administer our recruitment processes, and to provide updates on vacancies at Rockley which might be suitable for you, provided you have given your consent; and
  • To allow you to subscribe to news, alerts or other publications.

We will process Personal Data for the following purposes as necessary for certain legitimate interests, or where you have given your informed consent to such processing (such consent may be withdrawn at any time), including:

  • To offer our services to you in a personalized way;
  • To send you personalized marketing communications;
  • To allow you to participate in questionnaires, surveys, contests and surveys and benefit from personalized promotional offers;
  • To monitor quality control and ensure compliance with any and all applicable laws, regulations, codes and ordinances, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law;
  • To resolve any disputes;
  • As part of our efforts to keep our Site, services and premises safe and secure;
  • To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Site and services, for example, by requesting verification information in order to reset your account password (if applicable);
  • To administer our Site and services, and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To create products or services that may meet your needs; and
  • To develop and improve our products and services.

Cookies and Similar Technologies

We use cookies and similar technology to collect aggregate (non-personal) information about Site usage by all of our visitors and to help us remember you and your preferences when you revisit the Site. These cookies may stay on your browser into the future until they expire or you delete them. We also use technology to remember your purchase selections in your shopping cart. These cookies usually are erased when you close your browser window. Further general information about cookies and how they work is available at www.allaboutcookies.org.

We allow selected third parties to place cookies through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer’s online activities over time and across different websites when such third parties use our website. We may also permit third party service providers to place cookies through our Site to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.

We do not use technology that recognizes a “do-not-track” signal from your web browser.

Children’s Privacy

This Site is not designed nor intended to be attractive to use by children under the age of 13. We do not knowingly collect information from children under the age of 13. If you are under 13 please do not submit any information to us.

Accessing Your Information and Your Choices.

You can update, amend or delete your information at any time by emailing us at the address below. We will verify your identity before acting on your instructions.

You can choose not to receive promotional emails from us by “unsubscribing” using the instructions in any email you receive from us. This will not stop us from sending emails about your transactions with us.

You can choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies performance of the Site may be impaired and certain features may not function at all.

Sharing Your Information.

We may reveal information about you to unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.); (4) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets); (5) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); or (6) as otherwise described in this Privacy Policy.

We do not share your information with third parties for their marketing purposes.

We may disclose your non-private, aggregated, or otherwise non-Personal Information, such as usage statistics of our Products, to our affiliates and third parties.

Data Privacy Rights

In certain situations, and subject to applicable law, you may have certain rights in relation to your Personal Data.

Your European and United Kingdom Privacy Rights
For European and United Kingdom residents only. Under European and United Kingdom data protection law, in certain circumstances, you have the right to:

  • Request access to any Personal Data we hold about you (“Subject Access Request”) as well as related information, including the purposes for processing the Personal Data, the recipients or categories of recipients with whom the Personal Data has been shared, where possible, the period for which the Personal Data will be stored, the source of the Personal Data, and the existence of any automated decision making;
  • Obtain without undue delay the rectification of any inaccurate Personal Data we hold about you;
  • Request that Personal Data held about you is deleted;
  • Prevent or restrict processing of your Personal Data; and
  • Request transfer of Personal Data directly to a third party where this is technically feasible.

Also, where you believe that Rockley has not complied with its obligation under this Privacy Statement or UK or European law, you have the right to make a complaint to a UK or an EU Data Protection Authority, such as the UK Information Commissioner’s Office.

You can exercise any of these rights by contacting us using the Contact Us page or contact@rockleyphotonics.com.

We aim to respond to requests made by you within one (1) month, but may extend that period by two (2) further months where necessary.

Your California Privacy Rights
California residents are permitted by California law to request information about the manner in which we share certain categories of information with others for their marketing purposes. We do not share information with others for their marketing purposes.

California Consumer Privacy Act
At this time Rockley is not required to comply with the California Consumer Privacy Act (CCPA). We will update this Privacy Policy when we qualify for coverage under the CCPA.

For Site Visitors from Nevada
We do not transfer personal information for monetary consideration. If you would like to tell us not to sell your information in the future please email us at contact@rockleyphotonics.com with your name, postal address, telephone number, and email address with “Nevada do not sell” in the subject line.

Security

We use reasonable technical, administrative and physical measures to protect information contained in our system against misuse, loss or alteration. We may use standard encryption technology to protect information being transferred to our site, but no method of electronic transmission or storage is 100% secure.

Data Processing and Cross-Border Data Transfers

Our Site is maintained on servers located in the United Kingdom and elsewhere globally (including the United States of America), and personal information submitted is stored on our servers in the United Kingdom and the United States of America. If you are visiting our Site from outside the United Kingdom, please be advised that your information is transferred to our U.S. servers. Disclosing your personal information to us pursuant to this Privacy Policy is at your own risk. We strive to comply with laws of jurisdictions in which we maintain operations but we make no representations that the practices described in this Privacy Policy are compliant with laws outside those jurisdictions that apply to the collection, security, use and disclosure of personal information.

Where we transfer UK and European Economic Area Personal Data to a third party located in a country not recognized by the UK Government, European Commission, or another relevant body, as ensuring an adequate level of protection, we will take appropriate steps, such as implementing Standard Contractual Clauses recognized by the UK Government and EU Commission, to safeguard such Personal Data.

If you want further information on the specific mechanism used by us when transferring your Personal Data out of the UK or the EEA, please contact us using the contact details set out below.

Links to Other Sites

We may permit others to link to this Site or to post a link to their site on ours. We do not endorse these sites and are not responsible for other sites or their privacy practices. Please read their privacy policies before submitting information.

Changes to the Privacy Policy

As we grow and change we may amend this Privacy Policy. The Policy in effect at the time you use the Site governs how we may use your information. If we make material changes we will post the revised Policy and the revised effective date on this Site. Please check back here from time to time to review any changes.

Contacting Us

This Site is owned and operated by Rockley Photonics Limited. You can contact us at any address on our Contact Us page or at our headquarters office at 1 Ashley Road, Altrincham, Cheshire WA14 2DT United Kingdom, or by email at contact@rockleyphotonics.com.