Statement of Privacy Policy Last updated on Jan, 2023

PHASE Scientific International Limited (hereinafter called “We”, “Our Company” or “PHASE Scientific”) is committed to protecting your privacy. This Statement of Privacy Policy (“Privacy Policy”) applies to services provided under PHASE Scientific’s website and INDICAID mobile application (“Services”) and governs personal data collection and usage. By using the Services, you consent to the collection, use, disclosure of personal data and other descriptions in the Privacy Policy.

1. Collection of your personal information

PHASE Scientific collects personally identifiable information (PII), such as your e-mail address, name, photo, telephone number, geographical location and/or health and wellness-related data including point-of-care test results, when you submit PII through our online forms. PHASE Scientific also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, [nationality,] birthday, preferences, interests and favorites.

There is also information about your computer or portable device hardware and software that is automatically collected by PHASE Scientific. This information can include: your in-app usage information, IP address, device ID, browser type, domain names, access times, referring website addresses and Google Analytics. This information is used by PHASE Scientific for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the Services.

Please keep in mind that if you directly disclose your personally identifiable information or personally sensitive data through public message boards, discussion forums or other places provided by the Services, this information may be collected and used by others.

2. Use of your Personal Information

PHASE Scientific collects and uses your personally identifiable information to identify the users, respond to users’ requests or inquiries, operate the Services, deliver the Services you have requested and operate, evaluate and improve our business, including but not limited to product development, mobile application development, communications, data analytics, accounting, auditing and research.

PHASE Scientific may also contact you via email or through surveys to conduct research about your opinion of current services, and potential new or better services that may be offered by PHASE Scientific.

PHASE Scientific may make record of the websites and pages our customers visit when using services provided by PHASE Scientific, in order to determine what PHASE Scientific services are the most popular among PHASE Scientific’s customers or users.

3. Disclosure of your Personal Information

PHASE Scientific may share your personally identifiable information with our affiliates, business partners, service providers, other parties in connection with corporate transaction or other parties with your consent to help us to perform the Services or statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are required to maintain the same level of protection of personally identifiable information as stated in this Privacy Policy.

PHASE Scientific does not sell, rent or lease its customer lists to third parties without your explicit consent.

PHASE Scientific does not use or disclose sensitive personal information, such as race, religion, or political affiliations, except as required by the applicable law or your explicit consent is obtained.

4. Use of Cookies

PHASE Scientific may use Cookies to improve its website and enhance your online experience. Cookie refers to small text files stored on your device to facilitate us to track your activities in the website. Cookies may be used to remember your preferences when you visit the website and enable us to personalize the information shown in the website according to your needs. At any time, you can disable cookies by changing the settings of your web browser. See #12 Cookie Notice .

5. Direct marketing

Upon your consent, PHASE Scientific may use your name, mailing address, and email address to send promotional materials to you and conduct direct marketing activities in relation to the Services offered by PHASE Scientific.

If you do not wish to receive any of our promotional and direct marketing materials or do not wish to receive any such materials through any particular means of communication, please inform PHASE Scientific by sending your request by email at info@phasesci.com or post to Personal Data Officer, PHASE Scientific International Limited, 32/F, Gravity, 29 Hing Yip Street, Kwun Tong, Kowloon, Hong Kong.

6. Security of your Personal Data

PHASE Scientific will use its reasonable commercial endeavors to maintain in place security measures and monitoring procedures to protect your personal data and prevent unauthorized or accidental access, processing, erasure, loss or use of the data. All personnel that may access to the data will be ensured complying with the requirements of data protection.

7. Data Retention Policy

PHASE Scientific will retain your personal data as long as we need it for providing the Services to you and for a reasonable time after termination of the Services. Unless otherwise requested by you or required or permitted by the applicable law, we will retain your personal data for no more than 24 months following account deletion.

8. Changes to Privacy Policy

The Privacy Policy may be updated from time to time for any reason including customers’ feedback. PHASE Scientific will post the updated Privacy Policy here and encourages you to periodically review this Privacy Policy.

9. Enquiry

If you have any query in relation to the Privacy Policy or you wish to revoke your consent to this Privacy Policy or access, delete or correct your personal data held by PHASE Scientific, you can send your request by email at info@phasesci.com or post to Personal Data Officer, PHASE Scientific International Limited, 32/F, Gravity, 29 Hing Yip Street, Kwun Tong, Kowloon, Hong Kong. We will process your request in reasonable time.

10. Language

In the event of any inconsistencies or discrepancies between the English version and any other translated versions of this Privacy Policy, the English version shall prevail.

11. California Consumer Privacy Act (CCPA)

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category Examples Collected

A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
YES

B. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information
YES

C. Protected classification characteristics under California or federal law Gender and date of birth
NO

D. Commercial information Transaction information, purchase history, financial details, and payment information
YES

E. Biometric information Fingerprints and voiceprints
NO

F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
NO

G. Geolocation data Device location
NO

H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities
NO

I. Professional or employment-related information Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
YES

J. Education Information Student records and directory information
NO

K. Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
NO

L. Sensitive Personal Information
NO

We will use and retain the collected personal information as needed to provide the Services or for:
• Category B – As long as the user has an account with us
• Category I – As long as the user has an account with us

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in our privacy policy.

You may contact us by email at info@phasesci.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

PHASE SCIENTIFIC INTERNATIONAL LTD has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. PHASE SCIENTIFIC INTERNATIONAL LTD will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:
• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share personal information to third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling, or sharing personal information; and
• the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer’s sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights
• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at info@phasesci.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

12. Cookie Notice
What are cookies?

Cookies are small text files sent from a website you are browsing to your computer. Your computer stores the cookies inside your web browser. Cookies enable websites to recognize your browser and remember certain information. There are other technologies similar to cookies, these include electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs), unique identifiers that identify a browser, app, device or operating system and IP addresses used to connect your computer. All of these technologies, cookies and the others listed, allow us and our service providers to identify returning visitors and tell us things such as how many people visited our websites, the pages or content that were accessed, time spent on a page or website, and whether there were any technical problems in loading pages. We also use cookies and other technologies for security purposes and to display information more effectively. By collecting this information, we learn what parts of our websites are the most interesting or valuable to our visitors, and can monitor overall interest in, and functioning of, our websites. We also use them to ensure that advertisements you see online are more relevant to you and your interests, and we may use cookies to track responses and views of our advertisements. Cookies and other technologies are also used in emails to understand who opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

You can find more general information about cookies at: www.allaboutcookies.org/verify.

Does PHASE Scientific use cookies on its websites?

Yes. Like virtually all websites, our websites use cookies. Some of the cookies we use are temporary, called session cookies, and are discarded as soon as you end your session or close your web browser. Other cookies, called persistent cookies, remain on your computer’s hard drive for longer periods of time, after which they expire, or until you delete them.

Further, we use first-party and third-party cookies for the following purposes:

  • to make our websites function properly,
  • to improve our websites and Services,
  • to make login to our websites easier (such as by remembering your User ID),
  • to recognize you when you return to our websites,
  • to track your interaction with the websites,
  • to enhance your experience with the websites and Services,
  • to remember information you have already provided,
  • to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests, and
  • to provide a secure browsing experience during your use of our websites.
What are the types of cookies that PHASE Scientific Americas’ websites use?

Phase Scientific Americas may use cookies, embedded scripts, and other similar tracking technologies to collect additional personal information automatically as you interact with our websites and to personalize your experience with our websites. We also may use these technologies to collect information about your online activities over time and across third party websites. Third-party service providers may use information about your visits to other websites to target advertisements. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party’s website for more information on how they use cookies.

In general, there are four general categories of cookies that are used on websites:

  1. Strictly Necessary Cookies. These cookies are essential for you to use our websites. For example, strictly necessary cookies allow you to access secure areas on our websites. Without these cookies, some elements of our websites cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our websites to work and they cannot be disabled.
  2. Functional or Preference Cookies.We use functional cookies to remember your choices so we can tailor our websites to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our websites. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our websites.
  3. Performance or Analytic Cookies.These cookies collect passive information about how you use our websites, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our websites and services. We do not use these cookies to target you with online marketing. You may choose to disable these cookies.
  4. Advertising or Targeting Cookies.These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertising, and, in some cases, selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising to you on other sites. You may choose to disable the use of these cookies as set forth below.
Am I required to accept cookies to use this website?

No. Most web browsers automatically accept cookies, but most browsers also allow you to disable or manage the use of cookies to adjust the types of cookies you want to accept. Please note that if you choose to disable all cookies, some portions of our websites, as well as most other websites, may not work properly.

How do I block or manage cookies?

There are several ways you may be able to block or manage cookies. Certain of our websites offer cookie tools that provide information and allow you to manage your preferences. Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our websites by taking the steps outlined below:

  • First-Party Cookies.You can use the browser with which you are viewing the websites to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the websites. Also, if you disable cookies other parts of the websites may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
  • Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers.
  • Flash Cookies. Certain features of our websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our websites. If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage. Flash cookies are not managed by the same browser settings as are used for browser cookies, but may be managed here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending an email stating your request to info@phasesci.com. You can also opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://optout.aboutads.info/) or the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1). In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:

Do Not Track

Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our websites do not currently process or respond to “DNT” signals.