BioTrust, Inc.

Privacy Notice

This Privacy Notice was last updated on June 28 2026.

Who We Are

Welcome to the web site (the "Site") of BioTrust. PBC ("BioTrust," "we," "us," and/or "our"). The Site is operated by BioTrust and has been created to provide information about our company and the services we offer to our Site visitors and users ("you," "your"). This Privacy Notice ("Notice") sets forth how we process and use information including personally identifiable data ("Personal Data"), and how you may exercise any rights you may have regarding our processing of your Personal Data. BioTrust, or any of its subsidiaries or affiliates ("Related Companies"), will be responsible for the collection and processing of your Personal Data (known in some jurisdictions as the data controller).

Scope of this Privacy Notice

This Notice applies to Personal Data collected or processed by us online (through the Site, email, social media, and otherwise) (Online Services); when we process your Personal Data for your potential candidacy for access to our partners' products; when interacting with or visiting our sites and offices or our events (e.g., tradeshows and conferences); when we process your data as an employee of a company with whom we conduct business; when we process your data as a job candidate; or anywhere this Notice is posted or referenced. This Notice also applies to Personal Data that is collected or processed when you interact with us in person, by telephone, or by mail.

BioTrust may have other unique privacy notices that apply to certain specific situations, including informed consent forms. To the extent you were provided with a different privacy notice or policy and those policies or notices apply, those policies or notices will govern our interactions with you, not this one.
If you provide us with Personal Data of anyone other than yourself (such as a patient or family member), please note that you are responsible for complying with all applicable privacy and data protection laws prior to providing that information to BioTrust (including obtaining consent, if required).
Please review this Notice carefully. To the extent permitted by applicable law, by providing us your Personal Data or otherwise interacting with us, you are agreeing to this Notice.

Information Collected

"Personal Data" is any information-as electronically or otherwise recorded-that can be used to identify a person or that we can link directly to an individual, such as name, address, email address, telephone number, or credit card number, as applicable. Personal Data in some countries can include information that indirectly identifies a person, even absent other identifying information.

Personal Data may include information considered sensitive in some jurisdictions, such as biometric information, financial account information, geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, and other information. Data that could be considered Sensitive Personal Data is highlighted with an caret (^) in the summary charts below. We only collect and processes sensitive data for the purposes stated herein and do not use such data to infer characteristics about you.

We will process any Personal Data we collect in accordance with applicable law and as described in this Notice (unless, as explained above, a separate policy or notice governs). We use automated systems, including AI, to process personal data we collect; no solely automated decisions with legal or significant effects are made about you without human review. In some circumstances, if you do not provide us with your Personal Data, certain services may be unavailable to you.

Below is a summary of how we collect, process, and use Personal Data and the potential recipients of your Personal Data. Some jurisdictions require us to state the legal bases for processing your Personal Data, which are included below, but please note that not all jurisdictions may recognize all legal bases. The types of Personal Data we collect and disclose depends on your relationship with BioTrust. Not all of the categories listed in the following charts may apply to you. If the nature of your relationship with BioTrust changes, additional categories of Personal Data may also apply. BioTrust does not use or disclose Personal Data or sensitive Personal Data other than for the purposes specified herein.

Summary of personal data categories processed by audience
Audience	Identity and contact informationThis may include name, email, phone number, etc.	Other personal informationThis may include age, gender, date of birth, etc.	Visual and audio informationThis may include still images, video, call recordings, etc.	Technical informationThis may include Internet Protocol (IP) address, browser, device type, etc.	Commercial and financial informationThis may include request documentation, financial transaction history, etc.	Professional and educational informationThis may include job title or position, employer, etc.	De-identified dataData for which your individual personal characteristics have been removed****
Users of Online Services, Visitors at our Site(s), Visitors to our Physical Location and Events, Survey Participants, and Senders of Inquiries	X	X^	X	X^			X
Business Partners and Their Employees, Agents, and Contractors	X	X^	X	X^	X^		X
Employment and Apprenticeship Candidates	X^	X^		X^		X	X

Personal Data that may be considered sensitive is noted with a "^".

Users of Online Services, Visitors to Our Site(s), Visitors to our Physical Location and Events, Survey Participants, and Senders of Inquiries

We may process your Personal Data when you: (1) use our Online Services and/or visit our Site(s); (2) attend events and/or visit our physical locations; and/or (3) submit inquiries to us or respond to us both online (e.g., via email) or offline (e.g., by written letters).

Personal data processing details for Users of Online Services, Visitors to Our Site(s), Visitors to our Physical Location and Events, Survey Participants, and Senders of Inquiries
Examples of the types of data we process	Where do we get the data?	Why do we process the data?	The legal bases for processing	Who receives the data?
Identity and contact information first and last name email address postal address phone number company/employer Other personal information age gender^ marital status disability^ date of birth Visual and audio information still images^ video (including via CCTV)^ recordings of your calls with our customer service representatives Technical Information Internet Protocol (IP) addresses (which may identify your general geographic location or company) browser type and browser language device type advertising IDs associated with your device (such as Apple's Identifier for Advertising (IDFA) or Android's Advertising ID (AAID)) date and time you use our services Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Site activity on our Site and referring websites or applications data collected from cookies or other similar technologies geolocation information^ Anonymized / De-identified Data data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws***	you directly your devices our security systems (including CCTV) third parties	to provide you with our services to communicate with you (about your inquiry) to administer our relationship with your organization to send you updates to identify and authenticate you to customize content for you to detect security incidents to protect against malicious or illegal activity to ensure the appropriate use of our services to improve our services for short-term, transient use for administrative purposes for marketing, internal research, and development for quality assurance and to assist in training and development of our representatives to comply with our legal obligations, including any requirements under applicable legislation for any other purposes that are disclosed to you and to which you consent for any purposes required or authorized by law	for the purposes of our legitimate interests to comply with a legal obligation in preparation for or to perform a contract with you in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	BioTrust and its Related Companies partners that assist us in providing services or help us improve our marketing or administration** Our lawyers, auditors, and consultants Third parties that assist with fraud prevention, detection, and mitigation, information technology, security programs, and loss prevention programs

Business Partners and Their Employees, Agents, and Contractors

We may process your Personal Information when you act as a business partner such as a vendor, supplier, distributor, retailer, or service provider, when you engage us for credentialing services, or when we conduct candidacy evaluations for partner products.

Personal data processing details for Business Partners and Their Employees, Agents, and Contractors
Examples of the types of data we process	Where do we get the data?	Why do we process the data?	The legal bases for processing	Who receives the data?
Identity and contact information first and last name company/employer email address postal address phone number Other Personal Information age gender^ marital status disability^ date of birth Technical Information Internet Protocol (IP) addresses (which may identify your general geographic location or company) browser type and browser language device type advertising IDs associated with your device (such as Apple's Identifier for Advertising (IDFA) or Android's Advertising ID (AAID)) date and time you visit and use the Online Services Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Online Services activity on the Online Services and referring websites or applications data collected from cookies or other similar technologies geolocation information^ Commercial and financial information services purchased, obtained, or considered request documentation customer service records financial transaction history credit card number, expiration date, and CVV^ financial account number financial health information Anonymized / De-identified Data^ data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Information under data protection laws	you directly our business partners and other third parties your employer or principal your devices	to communicate with you to administer our relationship with your organization to send you updates to identify and authenticate you to detect security incidents to protect against malicious or illegal activity for short-term, transient use for administrative purposes for marketing, internal research, and development to provide you with our Online Services to comply with our legal obligations, including any requirements under applicable legislation for any other purposes that are disclosed to you and to which you consent for any purposes required or authorized by law	for the purposes of our legitimate interests to comply with a legal obligation in preparation for or to perform a contract in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	BioTrust and its Related Companies partners that assist us in providing the Online Services or help us improve our marketing or administration** Our lawyers, auditors, and consultants Third parties that assist with fraud prevention, detection, and mitigation, information technology, security programs, and loss prevention programs

Employment and Apprenticeship Candidates

We may process your Personal Data when you apply or are a candidate for employment or apprenticeship at BioTrust.

Personal data processing details for Employment and Apprenticeship Candidates
Examples of the types of data we process	Where do we get the data?	Why do we process the data?	The legal bases for processing	Who receives the data?
Identity and contact information first and last name company/employer email address postal address phone number username and password^ Other personal information age gender^ marital status disability^ date of birth Technical Information Internet Protocol (IP) addresses browser type and browser language device type advertising IDs associated with your device (such as Apple's Identifier for Advertising (IDFA) or Android's Advertising ID (AAID)) date and time you use our services Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Site activity on our Site, referring websites, or applications data collected from cookies or other similar technologies geolocation information^ Professional and educational information job title or position employer work skills employment history graduate degrees certifications specialized training responses to surveys and questionnaires Anonymized / De-identified Data data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws***	you directly your employer or principal your devices our business partners and other third parties	to communicate with you to identify and authenticate you to detect security incidents to protect against malicious or illegal activity for short-term, transient use for administrative purposes for marketing, internal research, and development to comply with our legal obligations, including any requirements under applicable legislation for any other purposes that are disclosed to you and to which you consent for any purposes required or authorized by law	for the purposes of our legitimate interests in preparation for or to perform a contract to comply with a legal obligation in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	BioTrust and its Related Companies partners that assist us in providing services or help us improve our marketing or administration** Our lawyers, auditors, and consultants Third parties that assist with fraud prevention, detection, and mitigation, information technology, security programs, and loss prevention programs

Footnotes

*The legal bases relied upon by BioTrust under the European Union's General Data Protection Regulation ("GDPR") include those enumerated in Articles 6 and 9, depending on the type of Personal Data. To the extent we process Personal Data for our legitimate interests, those interests include the processing purposes listed in the "Why we process the data" column.

**There are certain circumstances in which we may share your Personal Data with certain third parties. Those limited circumstances may include, (1) in the event of a sale, assignment, or transfer, to the buyer, assignee, or transferee; (2) to the extent we hire agents, consultants, or third parties to perform certain business-related functions; and, (3) government or regulatory officials, law enforcement, courts, public authorities, or others when permitted by this Notice or required by law.

***We will not attempt to re-identify you or anyone else from this Anonymized Data / De-identified Data, and if we disclose it to third parties, we will require that they commit to not attempting to re-identify you or anyone else from the Anonymized Data / De-identified Data.

****Each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us at: privacy@biotrust.org.

Cookies and Similar Technologies

To the extent permitted by law, including with your consent where required, we may engage in the following activities:

We may use your contact details to contact you to determine whether you would like us to send you marketing emails. If you do not wish to receive such marketing emails, you may opt out by declining to receive such emails when registering, in our subsequent communications by following opt-out or unsubscribe instructions included in the email, by contacting us, or at other information collection points.
We also perform statistical analyses of the users of our Online Services to improve the functionality, content, design, and navigation of our services.

This website may use certain tracking technologies, including "cookies," which from time to time automatically collect certain information and data. "Cookies" are small pieces of data sent to your computer browser from our web server and stored on your computer's hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of this website. Cookies also help us diagnose problems with our server and analyze how visitors use our website.

You may be able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies. However, if you block or otherwise reject cookies or similar technologies, certain websites (including this website) may not function as expected. Without refusing cookies through your browser, you can also opt out of Google Analytics by installing a Google Analytics Opt-out Browser Add-on for each web browser you use.

We do not sell or share your personal information. Furthermore, we have not sold or shared any categories of personal information about consumers with third parties in the preceding 12 months.

In addition, if you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. Visit http://www.allaboutcookies.org/manage-cookies/index.html for more information. If, however, you do not accept these cookies, you may experience some inconvenience in your use of our Online Services.

Certain web browsers and other programs may transmit "opt-out" signals, also called a Global Privacy Control (or GPC) signal ("GPC Signals"), to websites with which the browser communicates. You may need to change your web browser's settings or add an application to your web browser to enable your browser to send a GPC Signal. Our Online Services may recognize GPC Signals for visitors differently, based on the location of the visitor when they access our Online Services. For visitors that access our Online Services from jurisdictions that have laws requiring recognition of GPC Signals, we will recognize and apply the GPC Signal to inactivate targeted advertising and social media cookies; it will not inactivate required cookies, functional cookies, and analytics cookies. For others, our Online Services may or may not recognize and apply the GPC Signal.

To turn on GPCs on your browser, go to your browser, open the Privacy or Security Settings, locate the GPC or other Opt Out Preference Signal setting in your browser extension and turn it on. If your browser does not have this option, you will need to implement a browser extension that can send these signals.

Children

We do not knowingly collect Personal Data from children under the age of 16. If you are under the age of 16, please do not submit any Personal Data through the Site. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Notice by instructing their children never to provide Personal Data on the Site without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to us through the Site, please contact us, and we will endeavor to delete that information from our databases.

Third Parties

Combination of Data

We may combine information we collect, whether Personal Data or not, with Personal Data that we may obtain from third parties.

Third-Party Service Providers

Third-party service providers acting on our behalf must execute agreements including confidentiality requirements and will only process Personal Data as necessary to perform their functions in a manner consistent with this Notice, other applicable privacy notices, and as explicitly permitted or required by applicable laws, rules, and regulations. Our third-party service providers may be located in the United States and other jurisdictions.

Links to Other Web Sites

The Site may contain links to other web sites not operated or controlled by BioTrust (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Site do not imply that BioTrust endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Your Rights Regarding Your Personal Data

Please note that in many circumstances, we cannot effectively do business with you without processing some Personal Data about you (e.g., your contact information). For example, when you contact customer service representatives, we may require you to provide information to authenticate your identity to assist you with your request. If you are unable to provide this information, we may be unable to process your request.

Under your jurisdiction's data protection law, you may be able to exercise the following rights with respect to some or all of your Personal Data:

to request access to and a copy or representative summary your Personal Data (including under GDPR Article 15);
to request that we rectify or erase your Personal Data (including under GDPR Articles 16 and 17);
to request that we restrict or block the processing of your Personal Data (including under GDPR Articles 18, 21 and 22 and to object to the sale or sharing of your Personal Data under other relevant laws); this includes the right to opt out of solicitations;
to provide your Personal Data directly to another organization, i.e., a right to data portability (including under GDPR Article 20);
when we previously obtained your consent, to withdraw consent to processing (including under GDPR Article 21);
To request to know about the Personal Information we process about you or, in other states, to request to acknowledge our processing of your Personal Information;
To opt out of he use of automated decision-making technology when processing your Personal Information;
To request a list of the categories of third parties to which your Personal Information is disclosed or, in other states, to request a list of specific third parties (other than natural persons) to which we have disclosed your Personal Information;
to request that we limit the processing of your Sensitive Personal Data;
to appeal the denial of a request; and
To lodge a complaint with the data protection authority in your area (including under GDPR Article 77).

To exercise these rights, or make a request with respect to your Personal Data, please write to us at privacy@biotrust.org.

We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor the request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

Transfer of Personal Data Across National Borders

If you provide us with your Personal Data, you acknowledge that such Personal Data may be transferred from your current location to the offices and servers of BioTrust and the authorized third parties referred to herein, which may be located in the United States.

Please be aware that Personal Data we collect and process may be transferred and maintained outside your state, province, country, or other jurisdiction, where the privacy laws may differ to those in your location, including the United States. BioTrust has put in place safeguards in accordance with applicable legal requirements, to protect your Personal Data irrespective of the standards in the country where your Personal Data may be transferred. This includes entering into agreements with third parties, such as service providers, to require them to adopt standards that ensure an equivalent level of protection for data as those we adopt.

How Long Your Personal Data Will Be Retained

We will retain the categories of Personal Data discussed herein for as long as for as long as needed for the specific purpose or purposes for which it was collected or obtained, and as outlined in this Notice. In some cases, we may be required to retain Personal Data for a longer period of time as required by law or for other necessary or required purposes. Whenever possible, we aim to de-identify or anonymize your Personal Data or otherwise remove some or all information that may identify you from records that we may need to keep for periods beyond the specified retention period. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject that affects the length of time we need to keep your Personal Data; and (iii) whether retention is determined to be necessary for BioTrust due to limitation periods, litigation, or other legal or regulatory obligations. BioTrust takes reasonable steps to securely dispose of Personal Data upon the expiration of retention periods, taking into consideration these litigation, legal, or regulatory obligations.

Security

We take commercially reasonable steps to protect the Personal Data provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Site may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to us via the internet.

Changes to Our Privacy Notice

The Site and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Notice. We reserve the right to update or modify this Privacy Notice at any time and from time to time without prior notice. Please review this Notice periodically, and especially before you provide any Personal Data. This Privacy Notice was last updated on the date indicated above. Your continued use of the Site after any changes or revisions to this Privacy Notice shall indicate your agreement with the terms of such revised Privacy Notice.

Contact

If you have questions or comments about this Notice or about how your Personal Data is processed, please contact privacy@biotrust.org. We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor the request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

Email: privacy@biotrust.org
Mail: 1680 Mission St, San Francisco, CA 94103
Phone: 415-855-9912