CHROMacademy Privacy Policy

Introduction

Element Materials Technology Laboratory Solutions UK Limited (“Element”) together with MultiMedia Pharma Sciences, LLC are committed to protecting your privacy when you visit or use CHROMacademy.com (“Website”).

This Privacy Policy (“Policy”) applies to all personal information we collect, use and process about you when visit or use CHROMacademy.com. In this Policy, references to “we”, “us” or “our” are references to CHROMacademy.

Please read this Policy carefully as it contains important information to help you understand our practices regarding the use of your personal information.

Who is collecting Personal Information?

Any personal information provided by you or gathered in connection with use of our Website is controlled by Element Materials Technology Laboratory Solutions UK Limited, with a registered office at Rosewell House, 2a (1f) Harvest Drive, Newbridge, Midlothian, Scotland, EH28 8QJ and MultiMedia Pharma Sciences, LLC with a registered office at 2 Commerce Drive, Cranbury, New Jersey, 08512-3619 United States .

Element Materials Technology Laboratory Solutions UK Limited, together with other subsidiaries is part of the EM Topco Limited Group ("Element Group”) with a registered office at 3rd Floor Davidson Building, 5 Southampton Street, London, United Kingdom, WC2E 7HA.

MultiMedia Pharma Sciences, LLC is wholly owned subsidiary of MJH Life Sciences, LLC, with a registered office at 2 Commerce Drive, Cranbury, New Jersey 08512 United States.

What Personal Information Do We Collect?

We may collect and process your personal information in connection with our products or services at the start of, and for the duration of, your relationship with us and beyond. We will limit the collection and processing of your personal information to information necessary to achieve one or more legitimate purposes, as identified in this notice.

We will only process sensitive personal information where we’ve obtained your explicit consent or are otherwise lawfully permitted to do so. Where you have provided consent for us to process your sensitive persona information, you can withdraw that consent at any time by contacting us.

We may collect the following categories of personal information about you:

Personal Information Category	Personal Information Collected
Identity information	First name, last name, job title, organisation name
Contact information	Home, delivery, or billing address (including street address, city, state, town, postal code / zip code), telephone number, email address
Contractual information	Personal information (as outlined in the other categories) collected as part of the products and services we provide to you
Commercial information	Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Financial information	Bank account, payment card details, invoice amounts, payment amount, outstanding balances
Internet or another similar network activity information	Internet protocol (IP) address used to connect your computer to the Internet, information about your computer, your email address, password, and other log-in information, information about pages or products and services you have viewed or searched for
Information that we gather through cookies or similar tracking tools when you use our websites	Browser cookies, advertising cookies, targeting cookies, web beacon, pixel tag, mobile ad identifier, or similar technologies may also be used to track your responses to adverts, messages, or forms, which helps us to ensure we present you with the most relevant content in the future. When running email campaigns, we may track delivery and monitor when emails are opened. For example, when you open the email a small image file may be downloaded to your web browser or email programme. You can restrict or block this type of technology through your web browser or email programme settings by preventing automatic downloading. Cookies may also be set if you click on a link within the email.

How we collect your Personal Information

We collect your personal information in a variety of ways, such as:

- Through interactions with you when you enquired about or purchased products or services from us, become a paid subscriber, requested information or assistance from us, registered to attend or attended one of our events, used our website or client portal, or when you participate in product reviews, pilots, feedback sessions or similar

- Through activity on our website such as submissions from you via our website, on our community forums, or website usage details collected automatically

- Through interactions with our clients due to your role in your organization

- Through interactions with third parties such as industry, trade or regulatory bodies

- From third party service providers acting on our behalf in connection with the products and services we provide

- From publicly available sources including social media (LinkedIn, Facebook, Twitter), your organisation's website, the press, the electoral register, company registers and online search engines

- From automated technologies or interactions that collect technical data about your equipment, browsing actions and patterns such as cookies, server logs or other similar technologies

Purpose of processing your Personal Information

We will only use and share your personal information where it is necessary for us to carry out our lawful business activities. We collect and process your personal information for purposes detailed below:

Reason for Processing Personal Information	Purpose of Processing Personal Information
To fulfil our contractual obligations	- To provide our products or services to you - For you to provide your products or services to us
For our legitimate interest, as a commercial organization, provided our use is proportionate and respects your privacy rights	- To provide you with information on our products or services - To respond to a query, we have received from you - To review and improve our products and services and to help and support you in using our products and services - To confirm, update and improve our customer records - To review and develop your relationship with us - To inform you about improvements to our website - To troubleshoot problems with the Website, or to customize your experience on the Website - To conduct statistical analysis and research - To keep you informed of other products and services that may be of interest to you via email alerts, event registrations, social media activity, and other notices concerning our products or services, or events or news that may be of interest to you, including through targeted messages and advertisements on or through our websites and apps and through third-party websites and apps - To enforce our rights arising from any contracts entered between you or the entity you represent and us, including for billing and collections - To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as an ongoing concern or as part of bankruptcy, liquidation, or similar proceeding, in which your information held by us is among the assets transferred - To record information and feedback from you, including to enhance our products and services and for training and marketing purposes - For other reasons in connection with our business operations
To comply with a legal obligation	- To comply with our legal and regulatory obligations, which may require us to share your information.
You have provided your consent to the processing	- You provided your consent for us to process your personal information for a specific purpose.

If you do not provide us with your personal information when requested, it may prevent us from being able to carry out the tasks listed above.

Cookies and online tracking

Our websites use cookies to distinguish you from other users and to remember your preferences when you visit our website. Cookies are small files stored on a computer that are designed to hold small amounts of data specific to a user and the websites or applications to help tailor that user’s experience.

The permanent or persistent cookies we use remain on your computer after you leave the Website. The “Help” menu on most browsers will tell you how to get notice of a new cookie and how to disable cookies. However, disabling the cookie support function of your browser will prevent our Website from functioning smoothly (e.g., the Site won’t remember you as a prior visitor), and you may not be able to use fully all of the Site's features and information.

We enable advertising companies to develop banner and other ads for our Website, and the ads may contain cookies. These companies collect cookies sent to your browser through the ads, and we do not have control of, or access to, this data. In addition, we may publish site traffic statistics based on Google Analytics or other sources which are tailored to users based on information derived from cookies.

How we share your Personal Information

To help us provide our products and services to you and to run our website we may share your personal information when necessary for us to lawfully carry out our business activities. We may share your information with the following categories of third parties:

- Other Group companies where it is necessary to do so, and where we have a legal basis to share the information.

- Our third-party service providers and advisors with whom we have contracted to perform services on our behalf and who process information on our behalf to provide our services or run internal business operations including email distribution, IT services, business support and customer services.

- Independent debt recovery agencies, service providers, solicitors, or other agents in the event of non-payment for Products or Services and where a debt remains outstanding after a specified timeframe for payment, no payment plan is in place or an agreed payment plan is not being adhered to, we may initiate formal proceedings to recover the full amount of the unpaid debt. We may share your information with litigation and recovery specialists to undertake recovery action through the courts.

- Law enforcement authorities, regulatory bodies, or government agencies as in some circumstances we are legally obliged to share information with external bodies, for example to comply with a court order or legal obligation. We will satisfy ourselves that we have a lawful basis on which to share the information and document our decision making.

- With a successor entity in the event of a merger, acquisition, or similar transaction.

How we transfer your Personal Information

We operate globally and we may transfer your personal information between Group companies to help us operate our business efficiently and to provide you with our products and services.

Third party service providers may process your personal information in connection with a service, they provide to us. When we share your personal information between Group companies or with third parties, they may be located outside of the jurisdiction in which your personal information was collected. This means personal information collected in one jurisdiction may be transferred, stored, and processed outside the country of origin and where privacy laws differ. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect your personal information. For these transfers, we have the relevant legal safeguards in place, including (1) an Adequacy Decision in favor of the country of destination, (2) contractual arrangements based on Standard Contractual Clauses (“SCC”) pre-approved by the European Commission (or otherwise consistent with the requirements of the relevant jurisdiction) or Binding Corporate Rules (“BCR”) binding on the exporter and importer, plus a corresponding “transfer impact assessment” (“TIA”) and supplementary measures, or (3) an Article 49 exemption to the rules such as explicit consent that allows us to perform these transfers. Element and MultiMedia Pharma Sciences, LLC have executed a Data Transfer Agreement in accordance with the standard contractual clauses authorized by the European Commission.

Following the EU’s Adequacy Decision granted on 10 July 2023, the EU-US Data Privacy Framework (“DPF”), allows self-certified US businesses to freely receive personal data from the EEA without further measures. This means that for some transfers to the US, SCCs, TIAs and supplementary measures will no longer be required.

How we protect your Personal Information

We place great importance on the security of all information associated with our customers. We invest appropriate resources and use reasonable technical and organization measures, in compliance with applicable laws, to protect your personal information from unauthorized access, unlawful processing and against accidental loss, destruction or damage.

We have security and privacy policies in place which are regularly reviewed and enhanced as necessary. We store Personal Information on computer systems with access controls and personal data can only be access by authorized employees. If third-party contractors are required to access your Personal Information, they may do so for permitted business functions only.

When we transmit highly confidential information (such as a credit card number or password) over the Internet, we protect it using encryption, such as the Secure Socket Layer (SSL) protocol, an industry-standard security measure. Although we transmit the entire credit card number(s) to the applicable credit card company, we reveal only the last four digits of your credit card number(s) to confirm an order.

Please note your password to access to relevant portions of our Site should never be shared with anyone and should be changed frequently. Remember that any information you voluntarily disclose on-line in any news or message postings, discussion groups, or sponsored content may be collected and used by others without your permission.

Although we use reasonable efforts to secure network communications, the Website, and your personal information, we cannot ensure or warrant the security of any information you transmit to us by e-mail or via our Website, and you do so at your own risk.

Retention of your Personal Information

We will retain your personal information for as long as necessary to fulfil the purpose for which it was collected, such as providing our products or services, or as required by applicable laws or regulations. Our retention periods are driven by legislation and / or business need. If there is no legally defined retention period for personal information, we will determine an appropriate retention period. We will take reasonable steps to destroy personal information we hold if it is no longer needed.

Third-Party Websites and Affiliated Links

The Website contains links to other websites including suppliers, advertisers, and affiliates. We have no control over, and are not responsible for, the content of, or information gathered by, these other websites. We do not endorse any of these websites or the products or services associated with them merely because they are linked to our Website. Furthermore, if you provide any information to parties who operate these websites, you may be disclosing personal information, and different rules may apply to the collection, use, or disclosure of personal information on these sites. We encourage you to review third-party websites' policies before revealing any personal information or other sensitive information. We are not responsible for the privacy practices, terms of use, or the content of third-party websites.

Notice of Changes

Our business changes, and our Privacy Policy and Terms of Service will change also. We may email periodic notices about such changes, but you should check the Website frequently to see recent changes. We reserve the right, at any time and without notice, to add to, change, update or modify this Policy simply by posting the change, update, or modification on the Website. Any such change, update or modification will be effective immediately upon posting.

Marketing

We may send you information about our products and services that we believe may be of interest to you or your business. You may receive this information by letter, telephone, or email. If you no longer wish to receive these updates, please follow the unsubscribe link provided in every marketing email or contact [email protected].

Your Rights

Depending on jurisdiction, and subject to certain exceptions, you may have specific rights regarding your personal information, as detailed below:

Your Rights	Description of Rights
Right to know	You may have the right to know what personal information we process about you including: - what personal information processed - the categories of personal information being processed - the categories of sources from which the personal information was collected - the purpose of processing the personal information - the categories of third parties who the personal information is disclosed to
Right to access	You may have the right to access categories and specific pieces of personal information that we collect, use, and disclose about you
Right of rectification	You may have the right to ask us to rectify information you think is inaccurate or incomplete
Right to erasure	You may have the right to ask us to erase your personal information in certain circumstance
Right to restriction of processing	You may have the right to restrict the processing of your personal information in certain circumstances
Right to object to processing	You may have the right to object to the processing of your personal information in certain circumstances
Right to data portability	You may have the right to ask that we transfer any personal information you gave us from one organization to another or give it to you. We will provide the personal information in a structured, commonly used or in machine-readable format, and transmit it directly you or the required entity
Your right to opt out of sale of personal information	This right does not apply as Element does not sell personal information
Your right to non-discrimination	You may have the right to non-discrimination for exercising your rights. We cannot deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights

Notice to Nevada Residents

Nevada residents have the right to opt out of the sale of your personal information, including your first and last name; home or other physical address; e-mail address; phone number; and any identifier that enables you to be contacted online.

Notice to California Residents

California's "Shine the Light" law, Cal. Civ. Code § 1798.83, permits users who are residents of California to request and obtain from us, once per year, free of charge, information about their Personal Information, if any, that we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information includes a listing of the categories of Personal information that was shared and the names and addresses of the third parties with whom we shared the information.

Under the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”), residents of California are granted enhanced privacy rights and protections regarding their personal information. These rights include the ability to know what personal data is being collected about them, request the deletion of their data, opt out of the sale of their data, and correct any inaccurate personal information.

Rights Requests

If you would like to make a rights request, please submit your request to:

Email: [email protected]

UK and ROW number: +44 (0)1357 522 961

US, Americas & Pacific rim: (609) 819 5794

Postal address:

Online Privacy Coordinator
MultiMedia Pharm Sciences, LLC
2 Commerce Drive, Cranbury, NJ, 08512-3619 United States.

Privacy Manager
Element Materials Technology Laboratory Solutions UK Limited
1 New Park Square, Edinburgh Park, Edinburgh, Scotland, EH12 9GR

How to complain

If you would like to complain about how we have handled your personal information, please contact us at [email protected]. If you are unhappy with our response, you have the right to lodge a complaint with the relevant data protection supervisory authority:

- In the UK the supervisory authority is The Information Commissioners Office (ICO). To raise a complaint please visit their website https://ico.org.uk/make-a-complaint/

- In the EU details of the national data protection supervisory authorities can be found on the European Data Protection Board website at https://edpb.europa.eu/about-edpb/about-edpb/members_en. Contact information for the supervisory authorities may be found here: EU Data Protection Authorities

- In the United States the Federal Trade Commission (FTC) has authority to enforce privacy laws and take actions to protect consumers. You can report fraud, scams, and bad business practice on the federal government's website at https://reportfraud.ftc.gov/. Many US states also have their own data privacy and security laws, and state attorney general offices are responsible for overseeing these laws. State attorney general office contact details can be found at https://www.usa.gov/state-attorney-general.

Sale of Business

If we sell some or all our assets or our Website is acquired by a third party, your personal information will be among the transferred assets.

Contact Us

If you would like to speak to us about data protection you can do so by post, phone or email using the details below: