Privacy Policy

These terms went into effect on February 8, 2017 and were last updated May 25, 2018

Twist Bioscience Corporation (“we” or “Twist”) operates the website www.TwistBioscience.com (together with any associated or successor sites of Twist, collectively the “Site”) to provide information about our company, products and services and to offer certain related services. This Site includes the portal used by customers to order and purchase our synthesized DNA products as well as manage their accounts and access certain reports, tools and related functionality as may be provided by Twist from time to time (“Order System”). In this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual.

Twist has prepared this Privacy Policy to describe our collection, use, disclosure and protection policies and practices regarding the information we obtain from:

  • Visitors to the Site,
  • Customers who use the Order System, and
  • Contact persons at potential customers, customers, vendors and partners.

The Site is controlled and operated from the United States, and is directed only to individuals who are 18 years or older.

1. PERSONAL INFORMATION WE COLLECT

a. Information Provided by You

We may ask you to provide certain Personal Information when you register for an account, request information about a Twist product or service on the Site, or register for updates, newsletters or other communications through the Site. This Personal Information may include your name, email address, postal addresses, and telephone numbers. It may also include any information associated with your contact details, such as ordering information.  

We may also collect the Personal Information that you submit or post through the Site, such as demographic information and preferred methods of communication. For example, when you register for an account to use the Order System, and log into your account, we may collect your first name, last name, email, password, company or organization, and country. We may also collect your communications and content you submit to us or post on or through the Site.

b. Information Collected via Automated Means

We may collect Personal Information about you via automated means, such as cookies, web beacons and similar technologies. A “cookie” is a text file placed on a computer’s hard drive by a web server. In this context, we may collect certain information about you, such as browser and device information (e.g., device type, screen resolution, operating system version, and Internet browser type and version), actions taken on the Site, IP address and traffic patterns. We may also collect information about how you use and interact with the Site. For example, we may collect server log files, usage reports for tracking the total number of visitors to our website, the number of visitors to each page of our website, IP addresses, and the domain names of our users' Internet Service Providers, and we may analyze these data for trends and statistics in the aggregate, but such information will be in aggregate form only and it will not contain personally identifiable data.

Twist Site uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie, if opted into, about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

We use this information to facilitate your ongoing access to and use of the Site, present you with more tailored information about our products and services, collect and store information about your use of the Site, determine usage levels and activity, conduct data analysis, diagnose server problems, and operate and maintain the Site. 

c. Information from Third Parties

We may combine Personal Information that you submit on or through the Site with information that we collect from and about you from other sources, offline and online including the following:

  • Social networks when you reference our company or grant permission to Twist to access your data on one or more of these services.
  • Third party advertising network providers, advertisers, and other services to serve advertisements. These third parties may set and access cookies and other technologies on your personal computer and/or device and track certain behavioral information regarding users of your personal computer and/or device. These third party cookies and other technologies are set to track your activities across time and services for purposes of delivering relevant ads and/or other content to you (“Interest-based Advertising”). Any images (or any other parts of a web page) served by third parties in association with third party cookies may serve as web beacons, which enable third parties to carry out the previously described activities.
  • Our clients or other partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
  • Publicly-available sources such as open government databases or other data in the public domain.

d. Customer, vendor and Partner Relationships

We may obtain Personal Information of employees of customers, vendors and partners (e.g., professional contact details) via our customer, vendor and partner relationships

e. Tailored Content and Services

We may use your Personal Information, including information about your interactions with the Site, information about you provided by our partners, and publicly available information to analyze your preferences, interests and behavior in order to provide you with tailored content. 

2. HOW WE MAY USE PERSONAL INFORMATION.

We use Personal Information to do the following:

  • Provide the products and services that you request on the Site as well as customer support.
  • Send you administrative information, including information regarding the Site and changes to our terms, conditions and policies.
  • Personalize your experience on the Site by presenting content tailored to you.
  • Send you updates, messages and information about our products and services, including marketing communications. Where required under applicable law, we obtain consent to send you marketing communications
  • For our business purposes, such as data analysis, audits, developing or improving our products and services, enhancing the Site, identifying usage trends, and determining the effectiveness of promotional campaigns. For example, we may use this data to determine which parts of our site are of most interest to users, which parts are of least interest, and to modify the site accordingly.
  • As we believe appropriate (a) to comply with applicable law and legal processes; (b) to enforce our terms and conditions; (c) to protect our operations or those of our affiliates; (d) to protect our rights, privacy, safety or, or that of our affiliates, you or others; or (e) to allow us to pursue available remedies or limit the damages that we may sustain (these goals, collectively, the “Compliance Purposes”).
  • To aggregate information collected from the Site (including anonymization of Personal Information)
  • Manage our customer, vendor and partner relationships.

If you are located in the European Economic Area (“EEA”), we only process your Personal Information for the above purposes when we have a valid legal ground for the processing, including if:

  • You consented to the processing of your Personal Information. For example, we may seek to obtain your consent for our uses of cookies or similar technologies, or to send you marketing communications, if consent is required under applicable law.
  • We need your Personal Information to provide you with services and products requested by you, or to respond to your inquiries.
  • We have a legal obligation to process your Personal Information.
  • We or a third party, have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to ensure and improve the safety, security, and performance of our Site, and to anonymize Personal Information and carry out data analyses.
3. WHEN WE MAY DISCLOSE PERSONAL INFORMATION.

We do not sell, share, or otherwise disclose Personal Information we collect about you, except as described in this Privacy Notice or otherwise disclosed to you at the time of the collection.

Your Personal Information may be disclosed:

  • To our third-party service providers who provide services such as email delivery, payment processing, order fulfillment, hosting, data analysis, IT infrastructure, IT services, customer service, analytics providers, auditing and other services to enable them to provide such services. We require these service providers by contract to only process Personal Information in accordance with our instructions and as necessary to perform services on our behalf or comply with legal requirements.
  • By you, if you choose to submit content to be posted on a public portion of the Site. WE ARE NOT RESPONSIBLE FOR THE USE OR DISCLOSURE BY OTHER SITE USERS OF ANY INFORMATION THAT YOU VOLUNTARILY SUBMIT TO PUBLIC PORTIONS OF THE SITE.
  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with a bankruptcy or similar proceeding).
  • To our subsidiaries and other affiliates who are subject to this Privacy Policy or policies and practices at least as protective as those contained in this Privacy Policy, and to which it is reasonably necessary or desirable for us to disclose your Personal Information in order to carry out the above-mentioned purposes.
  • As we believe appropriate for Compliance Purposes (defined above).
4. DATA SECURITY AND RETENTION

We maintain administrative, technical and physical safeguards designed to protect the Personal Information you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We may use third party hosting and cloud services to store and process your Personal Information on our behalf. We endeavor to select and use such services with data security in mind so that your information is subject to appropriate safeguards and protection. However, no data transmission over the Internet or data security system can be guaranteed to be 100% secure (subject to requirements under applicable law to ensure or warrant information security).

We may retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.  For example, we may retain sequence information you provide to us to the extent required by applicable laws and regulations.  Subject to the terms of any Supply Agreements and the requirements of applicable laws and regulations, we may delete your Personal Information at any time and have no obligation to store or retain such information.

We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required or permitted by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

5. YOUR RIGHTS AND CHOICES

a. Your choices regarding our use and disclosure of your Personal Information.

We may give you choices regarding our use of your Personal Information for our marketing and related purposes. You may opt-out from receiving marketing-related messages from us either by using the unsubscribe mechanism provided in the email or by emailing us at privacy@TwistBioscience.com. If you opt out from receiving marketing-related messages from us, we may still send administrative, operational and support messages to you. 

b. Your choices regarding cookies.

If you do not want our cookies to collect information about you, there is a simple procedure on most devices that allows you to decline the use of cookies.  To learn more about cookies, please visit http://www.allaboutcookies.org/.  However, if you choose to decline cookies, then some or all of the features, functionality and promotions available through the Site may not be available to you. Our Site does not respond to browser-based do-not-track signals.

c. How you can access, change or remove your Personal Information and Posted Content.

If you would like to review, correct, update, or delete your Personal Information that you have previously provided to us or content you have previously posted on the Site, you may be able to do so through your account on the Order System or other self-help functionality on our Site (to the extent the Order System or other parts of our Site allow for such functionality). Otherwise, you may contact us by emailing us at privacy@TwistBioscience.com.  We will try in good faith to comply with your request if reasonable but make no commitments that we will do so, except if required under applicable law. Furthermore, we may need to retain certain information for recordkeeping purposes and for Compliance Purposes, except if such retention is not permitted under applicable law. There may also be residual information that will remain in our databases and other records that will not be removed, except if removal if required under applicable law. We are not responsible for changing, removing or suppressing information from the databases of third parties that have previously accessed your information, with the exception of any responsibility we may have under applicable law for notifying third party data recipients of any changes, removal or suppression that we carried out, if applicable.

d. Rights and choices in certain jurisdictions.

In some countries and in particular if you are located in the EEA, you may have the right to:

  • Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
  • Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

Those rights may be limited in some circumstances by local law requirements.

You may exercise your rights by contacting us as specified below. Note, however, that if you exercise your right to object or your rights of restriction or deletion, if you decline to share certain information with us, or if you withdraw your consent to our processing of Personal Information about you, we may not be able to provide to you some of the features and functionalities of the Site. 

6. DATA TRANSFERS

We may transfer or disclose Personal Information we collect about you to the United States where our headquarters are located and where the servers that we use are located. [These countries/The United States] may not have the same data protection laws as the country in which you initially provided the information. When we transfer your Personal Information, we will protect that information as described in this Privacy Policy. If you are a user located outside the United States, you understand and consent to having any Personal Information processed in the United States.  

[If you are located in the European Economic Area (“EEA”), we comply with applicable legal requirements to provide adequate safeguards for the transfer of Personal Information to countries other than the country where you are located. In particular, may transfer Personal Information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Information, such as the European Commission's Standard Contractual Clauses, or rely on third parties’ certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks where applicable. You may contact us as specified in the “Our Contact Information” section below to obtain a copy of the safeguards we use to transfer Personal Information outside of the EEA.]

7. CALIFORNIA PRIVACY RIGHTS

California law permits residents of California to request certain details about what personal information a company shares with third parties for the third parties’ direct marketing purposes. We do not share your Personal Information with third parties for the third parties’ own and independent direct marketing purposes unless we receive your permission.

8. LINKS TO OTHER SERVICES AND APPLICATIONS

Our Site and its services (including the Order System) may contain links to, interoperate with, and allow you to share content to and from third party services, websites and applications. The fact that we link to a website, service or application or allow you to share content through these third parties is not an endorsement, authorization or representation that we are affiliated with that third party, nor is it an endorsement of their privacy or information security policies or practices. Other websites, services and applications follow different rules regarding the collection, use, storage or disclosure of the personal and other information. We encourage you to read the privacy policies or statements of the other websites, services and applications you use.

9. LIMITATION OF LIABILITY

Even though Twist has taken reasonable commercial steps and efforts to prevent Personal Information from being accessed, used, intercepted or disclosed by unauthorized individuals in violation of this Privacy Policy, you should know and you acknowledge that Company cannot fully eliminate security risks associated with your information.  Subject to the terms of any Supply Agreements, you expressly acknowledge and agree that uploading, posting, providing, storing, transmitting, sharing and/or allowing access to Personal Information and Other information on, through or to the Site, and the use of the products and services on the Site, are all done at your sole risk and responsibility. You expressly acknowledge that, except to the extent expressly provided for in any Supply Agreements, Company is not liable for (i) any special, indirect, consequential, incidental or punitive damages, costs, or liabilities whatsoever arising out of or resulting from your use of the Site, including from uploading, posting, providing, storing, using, analyzing, transmitting, sharing and/or allowing access to Personal Information and Other Information; or (ii) any loss, disclosure or use of your Personal Information or Other Information.

10. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. We will notify you of important changes, either by posting a notice on the Site or sending you an email. The Privacy Policy posted on the Site will say when it was last changed, and when a new version will go into effect. If you continue to use the Site after a change, then you have accepted the new Privacy Policy. If we update this Privacy Notice, in certain circumstances, we may seek your consent.

11. HOW TO CONTACT US

The entity responsible for the processing of your Personal Information is Twist Bioscience Corporation. 

Withdrawing Consent

If you wish to withdraw your consent, please contact us by email at privacy@TwistBioscience.com, or write to the following address: Twist Bioscience Corporation, Attn: General Counsel, 455 Mission Bay Boulevard South, San Francisco, CA 94158, United States. Please note that if you withdraw consent, we may not be able to provide or continue to provide certain services or marketing communications to you.

Objection and Requests for Copies

If you wish to (i) object, for legitimate purposes, to the processing of personal data as provided under applicable law, or (ii) to request copies of your personal data held by us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible), please write to us at the following address:

Twist Bioscience Corporation
Attn: General Counsel
455 Mission Bay Boulevard South
San Francisco, CA 94158
United States
RE: GDPR Privacy
Requests for Deletion

If you wish to request that we delete your personal data, please contact us by email at privacy@TwistBioscience.com, or write to the following address: Twist Bioscience Corporation, Attn: General Counsel, 455 Mission Bay Boulevard South, San Francisco, CA 94158, United States. We will promptly send you a verification email to the email address provided to us and respond to your request to delete your information within one month of receipt of your verification. Our response period may be extended by 60 additional days where necessary, taking into account the complexity and number of requests we receive. We may need to retain certain records, for example those relating to open orders, payments, or customer service matters, for legal and accounting purposes. 

If you have multiple email addresses linked to your account (or you used multiple email addresses in connection purchases) you may need to make a data deletion request with respect to each email address in order for us to fully delete your personal data.

Questions

If you have any questions about this Privacy Policy, please contact us by email at privacy@TwistBioscience.com, or write to the following address: Twist Bioscience Corporation, Attn: General Counsel, 455 Mission Bay Boulevard South, San Francisco, CA 94158, United States.