Last updated: March 30th, 2022

SUMMARY

At 9xchange, we value your privacy. 9xchange does not run ads. We collect information from you that is essential to offer our service. We use Google Analytics (and its cookie) to better understand how our service is used, and how we can make it better. Other cookies are needed to offer our service in a secure way.

THE DETAILS

9xchange or 9XC, owned and operated by 9xchange Ltd. (“we”, “our”, “us”) is committed to protecting and respecting your privacy. We are a limited liability company established in Israel with a registered company number of 516477809 and for the purpose of applicable data protection laws, we are the data controller. Our representative in the European Economic Area and the UK is DataRep Other ways of contacting Datarep (including physical addresses in selected countries) can be found here.

This Privacy Policy sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of our website at www.9xc.co (our “Website”) and in connection with our provision of a molecule marketplace platform we provide to you (together, the “Services”).

Please read this Privacy Policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. This Privacy Policy supplements any other privacy related notices and policies we may provide to you from time to time, and is not intended to override them. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Website, use our Services or otherwise provide your information to us.

Our Website and Services are not intended for children under 16 years of age. As a general rule, children under 16 years of age are not allowed to use the Services and we do not knowingly collect data relating to children. If we learn that we have collected personal information of a child, we will delete it. We encourage any parents with concerns to contact us via the methods in Section 13.

We change our Privacy Policy from time to time. Updates to our Privacy Policy will apply only to information collected after the date of the change. We will note on our Website when our Privacy Policy has been updated. Please check the Website regularly for notices of changes to our Privacy Policy.

1. THE INFORMATION WE COLLECT
   
   

   • Information you give to us. You may provide some or all of the following personal data to us by subscribing to our Services: First name, last name, job title, email address, profile picture (optional), telephone number, postal address, payment card information (optional, if you choose to use your personal card to purchase on the Services). This information is required to enable us to fulfil our contract with you. If you do not provide this information, we will not be able to provide you with our services.
     
     
   • Information we collect automatically. When you visit our Website and use our Services, we automatically collect the information sent to us by your computer, mobile phone or other device. This information includes: (i) your IP address; (ii) device information including, but not limited to, name and type of operating system; (iii) mobile network information; (iv) standard web information such as your browser type and the pages you access on our Website; (v) transaction information - including device information, transaction details, and IP address; (vi) security information including a list of certain installed software, device and internet connection information, and available space on the device; and (vii) activity information including your activities whilst using the Website and/or Services.
     
     

2. HOW DO WE USE YOUR INFORMATION?
   
   

   1. We process your personal data in order to perform our contract with you, such as to:
      
      
      • provide you with our Services, other content and Website functionality
      • register and maintain your account with us
        
        
   2. We obtain your consent to process your personal data for the following reasons:
      
      
      • sign you up for our newsletters or alerts;
      • personalize our services for you; and
      • if you opted into marketing, to communicate with you about products, services, marketing, promotions, events and other news and information we think will be of interest to you.
        
        
   3. In order to be responsive to you, to provide effective services to you, and to maintain our business relationship, as a matter of our legitimate interests, we will use your personal data to:
      
      
      • administer the Website and Services, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
      • maintain the safety and security of our users, the Website, our Services, and business;
      • send you announcements in relation to security, privacy or administrative related communications (these communications are not marketing oriented, and we do not rely on consent, so you may not opt out);
      • personalize our Website and our Services to ensure content is presented in the most effective manner for you and your device; and
      • improve and develop our products.
        
        
   4. In addition, we will use some or all of the above information to comply with any applicable legal obligations, to enforce any applicable terms and conditions and/ or terms of service, and to protect or defend the Services, our rights, the rights of our users, or others.
      
      
   5. We also may use third party platforms, such as LinkedIn, to confirm your identity.
      
      

3. COOKIES
   
   We use cookies and other similar technologies to collect information about your browsing activities over time and across different websites following your use of our Services. Cookies allow us to recognize and count the number of users and to see how users move around our website when they are using it. This helps us to improve our Services and the way our website works. You can find more information about cookies and how to manage them.
   
   

4. HOW THE COMPANY SHARES YOUR INFORMATION
   
   We do not use or share your personal data with others except as described in this Privacy Policy. In certain circumstances, we may share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law. Specifically, we may share your personal data:
   
   

   • With service providers and vendors for business purposes in our legitimate interests, or to perform a contract with you. Such third parties include: (i) data analytics vendors; (ii) security vendors; and (iii) website hosting vendors. These service providers assist us with many different functions and tasks, such as providing data storage and disaster recovery services and communicating with you.
   • When you request us to share certain information with third parties, with consent or to perform a contract with you. With your permission or upon your discretion, we will disclose your personal data to relevant third parties.
   • With professional advisors, in our legitimate interests or as required by law. As necessary, we will share your personal data with professional advisors functioning as service providers such as auditors, law firms, or accounting firms.
   • For legal and security reasons and to protect our services and business, in our legitimate interests or as required by law. We will share your personal data with regulators, law enforcement agencies, public authorities, or any other relevant organizations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security, of us, our users, a third party or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements
   • With our affiliates, in our legitimate interests. We may share your personal data with companies within our corporate family.
   • In connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organization of 9xchange, in our legitimate interests. We will share your personal data with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.
     
     

5. WHERE WE STORE YOUR INFORMATION
   
   The personal data that we collect from you will be transferred to, and stored at/processed in countries outside the European Economic Area (“EEA”) and the United Kingdom (“UK”). Your personal data is also processed by staff operating outside the EEA and the UK who work for us or one of our third party service providers or partners. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.
   
   For any transfers of data outside the EEA or the UK, the data transfer will be under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses) (the “Model Clauses”), or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data. Please contact us at [email protected] should you wish to examine a copy of the Model Clauses.
   
   

6. HOW LONG DO WE STORE YOUR PERSONAL DATA?
   
   We will retain your personal data as follows:
   

   • your account data for as long as you keep your account open or as needed to provide you with our Services;
   • if you contact us and request deletion, we will keep your data for 30 days after you contact us;
   • your technical usage information for 24 months; and
   • data on your use of our Website and our Services is retained for 24 months.

   We will also retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies. If you stop using our Services or if you delete your account with us, we will store your information in an aggregated and anonymized format; we may use this information indefinitely without further notice to you.
   
   

7. SECURITY
   
   Although we do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over email, text/SMS, or instant chat; any transmission is at your own risk.

8. EEA/UK USER RIGHTS
   
   If you are located in the EEA or the UK, you have certain rights in relation to your personal data:

   • Access: You have the right to access personal data we hold about you, how we use it, and with whom we share it.
   • Portability: You have the right to receive a copy of the personal data we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
   • Correction: You have the right to correct any of your personal data we hold that is inaccurate.
   • Erasure: In certain circumstances, you have the right to delete the personal data we hold about you.
   • Restriction of processing to storage only: You have the right to require us to stop processing the personal data we hold about you, other than for storage purposes, in certain circumstances.
   • Objection: You have the right to object to our processing of your personal data.
   • Objection to marketing: You can object to marketing at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you.
   • Withdrawal of consent: Where we rely on consent to process your personal data, you have the right to withdraw this consent at any time by emailing us a [email protected]

   Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your personal data. To exercise any of these rights, please submit a request according to Section 10 below.
   
   

9. CALIFORNIA USER RIGHTS
   
   Under the California Consumer Privacy Act (“CCPA”), California residents are afforded certain rights about Personal Information (as the term is defined under the CCPA) that we collect, use, and share about them, which we have described in more detail below. For the purposes of this section, Personal Information does not include information exempted from the scope of the CCPA.

   Personal information that we collect, use, and share

   • Identifiers, including your name, telephone number, postal address, email address. These data types include Personal Information listed in the California Consumer Records statute (§ 1798.80(e)).

     • We collect this information directly from you.
     • We collect this information to provide you with the Services; register and maintain your account with us; to communicate with you; and maintain the safety and security of our users and the Services. For more information, see Section 2 entitled “How Do We Use Your Information?”
     • We may also share this information with other users as part of the general operations of the Services pursuant to the Marketplace Process.

   • Professional and employment related information, including your job title.

     • We may collect this information directly from you. We may collect additional information from third-party social media networks, such as LinkedIn.
     • We collect this information to provide you with the Services; register and maintain your account with us; and maintain the safety and security of our users and the Services. For more information, see Section 2 entitled “How Do We Use Your Information?”
     • We may share this information with professional service providers, such as data analytics vendors, security vendors, and website hosting vendors, who help us provide the Services to you.
     • We may also share this information with other users as part of the general operations of the Services pursuant to the Marketplace Process.

   • Financial information, including payment information, such as if you choose to provide a personal credit card to pay your subscription fee.

     • We may collect this information directly from you.
     • We may collect this information to provide you with the Services; and register and maintain your account with us.
     • We may share this information with professional service vendors, such as payment card vendors, who assist us with processing payments related to your use of the Services pursuant to the Marketplace Process.

   • Internet or other electronic network activity, such as IP address and cookies.

     • We collect this information automatically from your computer or device.
     • We collect this information to provide you with the Services; personalise our Services for you; maintain the safety and security of our users; administer the Services and for internal operations in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis; and improve and develop our products.
     • We may share this information with professional service providers, such as data analytics vendors, security vendors, and website hosting vendors, who help us provide the Services to you pursuant to the Marketplace Process.

   • Audio, electronic, visual, and similar information, such as your profile picture if you choose to provide it.

     • We collect this information directly from you.
     • We collect this information to register and maintain your account with us; and provide you with our Services.
     • We may share this information with other users as part of the general operations of the Services.

   Your California privacy rights

   As a California resident, you may have the rights listed below in relation to the Personal Information we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

   • Information: You can request information about how we have collected and used your Personal Information during the past 12 months, including the categories of personal information that we have collected; the sources of such personal information; the business or commercial purposes for which we have collected such personal information; the categories of personal information that we have sold or disclosed; and the categories of third parties to whom we have sold or disclosed the personal information.
   • Access: You can request a copy of the Personal Information that we have collected about you during the past 12 months.
   • Deletion: You can request that we delete the Personal Information that we have collected from you.

   We will not discriminate against you for exercising any of your rights under CCPA.

10. EXERCISING YOUR RIGHTS
    
    To exercise any of your rights under the privacy laws applicable to you, you may contact us via email at [email protected]. If you are a resident of the EEA or the UK, we will respond to requests to exercise these rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). If you are a resident of California, we may need to collect information from you to verify your identity, such as your email address, government issued ID or date of birth, before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

11. THIRD PARTY LINKS
    
    Our Website may contain links to other online platforms, plug-ins or other applications operated by third parties. We do not control such other sites or applications, and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms, may also be viewable by other users of the Website and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Website. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal data by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

12. COMPLAINTS
    
    If you have complaints about how we process your personal data, please contact us at [email protected] and we will respond to your request as soon as possible. If you are a resident of the EEA or the UK and you think we have infringed data protection laws, you can file a claim with the data protection supervisory authority in the EEA country in which you live or work or where you think we have infringed data protection laws, or with the UK Information Commissioner’s Office, as applicable to you.

13. CONTACT
    
    We welcome your questions, comments, and concerns about this Privacy Policy or your personal data. Please send us any feedback to [email protected].

14. LANGUAGE
    
    Except as otherwise prescribed by applicable law, in the event of any inconsistency between the English language version and local language version of this Privacy Policy, the English language version will prevail.