CALIFORNIA PRIVACY NOTICE

This CA Notice went into effect on January 1, 2020  

Scope of Disclosures

 

This California Privacy Notice (the “CA Notice”) supplement the information contained in our Privacy Policy and applies solely to individual residents of the State of California (“consumers” or “you”). 

This CA Notice provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).  

Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA. 

Our Processing of Personal Information

 

When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. 

 

For the purposes of this CA Notice, personal information does not include: 

 

  • Publicly available information from government records.
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
  • Information excluded from the CCPA's scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994. 
  • Information relating to our job applicants, employees, contractors and other personnel.
  • Information about our interactions with our B2B contacts.

 

Collection and Use of Personal Information

 

In the last 12 months, we have collected the following categories of personal information from the following sources for the following purposes, which reference the personal information, sources and purposes described in the Personal Information We Collect and How We May Use Personal Information sections of our Privacy Policy

 

Category of Personal Information Collected Categories of Sources Commercial or Business Purpose
Identifiers, such as name, email and mailing address, telephone number, account username and password, persistent online identifier (e.g.  persistent cookie, IP address, MAC address), internal Twist identifiers, and social media accounts information
  • Directly from you
  • Your browser or device
  • Data providers
  • Publicly available sources
  • Social media networks
  • Common Purposes Described Below
  • To fulfill your orders
  • To communicate with you
  • To provide customer support
  • To provide you information about our services
  • To invite you to participate in surveys, research and events
  • For collaboration with third parties
  • For marketing purposes
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as contact information, credit card number, debit card number
  • Directly from you
  • Data providers
  • Publicly available sources
  • Social media networks
  • Common Purposes Described Below
  • To fulfill your orders
  • To communicate with you
  • To provide you information about our services
Commercial Information, such as purchase/transaction history.
  • Directly from you
  • Common Purposes Described Below
  • To provide customer support
  • To provide you information about our services
  • To invite you to participate in surveys
  • For collaboration with third parties
  • For marketing purposes
Internet/Network Information, such as device name, device ID, browsing history, browser type, interaction with website or online advertisement
  • Your browser or device
  • Data providers
  • Publicly available sources
  • Common Purposes Described Below
  • To contact you
  • To provide you information about our services
  • For marketing purposes
Other Personal Information, such as inquiry information, your questions/feedback to us, survey responses, tax exempt status information, active/inactive status of your Twist account
  • Directly from you
  • Your browser or device
  • Common Purposes Described Below
  • To communicate with you
  • To provide customer support
  • To provide you information about our services
  • To facilitate your participation in surveys, research and events
  • For collaboration with third parties
  • For marketing purposes
Inferences, such as inferences and analytics based on your purchase/transaction history, based on preferences that you provide us or that we observe (e.g. product preferences, communication preferences)
  • Directly from you
  • Your browser or device
  • Data providers
  • Publicly available sources
  • Social media networks
  • Common Purposes Described Below
  • To provide you information about our services
  • To facilitate your participation in surveys, research and events
  • For marketing purposes

 

In addition to the specific commercial and business purposes identified above, the following “Common Purposes” apply to all categories of personal information we collect: 

  • To better serve you;
  • To provide you our Site and Order System;
  • To personalize your experience on the Site;
  • To send you promotional offerings;
  • To enhance our products, services and operations;
  • To enable online security;
  • For research purposes;
  • To prevent fraud;
  • To comply with legal process and our legal obligations;
  • For business transactions;
  • As otherwise provided in our agreements with you. 

Disclosure of Personal Information

In the last 12 months, we have disclosed for a business purpose and sold the following categories of personal information, which reference the categories of personal information described above: 
 

Category of Personal Information Disclosure for a Business Purpose Sold*
Identifiers
California Customer Records(Cal. Civ. Code § 1798.80(e))
Commercial Information
Internet/Network Information
Other Personal Information
Inferences

 

*Twist does not “sell” personal information about our customers as most people would typically understand that term.  However, we do allow certain third-party advertising partners to collect information about the users of our Site for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting.  To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see our Third-Party Tracking and Online Advertising section below for more information. 

As described in the When We May Disclose Personal Information section of the Privacy Policy, we share Personal Information within Twist and with a variety of third parties for business purposes. 

 

Third-Party Tracking and Online Advertising

We utilize third-party partners to collect the categories of personal information identified above for online advertising purposes. These ad networks, social media companies and other third-party businesses collect your personal information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our websites, use our apps or otherwise engage with us online. These third-party businesses use your personal information to serve relevant ads on our site, on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third parties may use such personal information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks

Please see our Privacy Policy for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.

Your California Privacy Rights

 

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law)

The Right to Know You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:
  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information we have collected about you;
  • The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold about you, and the categories of third parties to whom this information was sold; and
  • The business or commercial purposes for collecting or selling personal information about you.
The Right to Request Deletion You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt-Out of “Sales” You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Non-Discrimination You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

 

How to Exercise Your California Privacy Rights 

 

To Exercise Your Right to Know or Right to Deletion

To exercise your right to know and/or right to deletion, please submit a request by: 

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems.  Although we try to limit the personal information collected in connection with a request to exercise the right to know or the right to deletion, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know or right to deletion, particularly where we are unable to verify your identity. 

To Exercise Your Right to Opt-Out of Personal Information Sales


We do not engage in sales of personal information; however, as a California resident, you may submit a request to opt-out of potential future sales under California law by emailing privacy@TwistBioscience.com with the subject line “California Opt-Out Request”.  Please note we will take reasonable steps to verify your identity and the authenticity of the request.  Once verified, we will maintain your request in the event our practices change.

Updates to This CA Notice


We will update this CA Notice from time to time. When we make changes to this CA Notice, we will change the effective date at the beginning of this CA Notice. If we make material changes to this CA Notice, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us


If you have any questions or requests in connection with this CA Notice or other privacy-related matters, please send an email to privacy@TwistBioscience.com, or write to the following address: 

Twist Bioscience Corporation 
Attn: General Counsel
681 Gateway Blvd
South San Francisco, CA 94080 
United States