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General Oligo, Inc. (“General Oligo,” “we,” or “us”) is committed to handling your personal and scientific information responsibly. This Data Usage Policy describes what information we collect through the General Oligo NAB Configurator, the Accessories Shop, and related interactions, how we use it, how we protect it, and your rights with respect to your data.

This policy applies to customers and prospective customers who interact with General Oligo through any General Oligo ordering platform, our website at generaloligo.com, or by contacting us directly.

By placing an order through any General Oligo ordering platform or otherwise providing information to General Oligo, you acknowledge that you have read and understood this policy.

1. Information We Collect

We collect the following categories of information:

1.1 Customer Account and Contact Information

When you register for an account or place an order, we collect:

• Full name
• Company or institution name
• Email address
• Phone number
• Shipping address

1.2 Order and Configuration Data

We collect the full details of each order placed through any General Oligo ordering platform, including:

• NAB configuration selections (backbone type, modification type, modification density, production scale, formulation, and other parameters)
• Research Kit and Accessory order selections (product names, SKUs, quantities, and selected options)
• Order pricing and payment confirmation records. Payment processing is handled by our third-party payment processor, Stripe. General Oligo does not store or have access to your full payment card details.
• Order status and fulfillment history

2. How We Use Your Information

General Oligo uses the information we collect for the following purposes:

• Order fulfillment — to process, produce, and ship your order
• Order communications — to send you order confirmations, production status updates, shipping notifications, and any follow-up required to complete your order
• Customer support — to respond to questions, claims, or requests related to your order
• Quality assurance — to maintain accurate production and fulfillment records and support ongoing quality control of our Products
• Internal recordkeeping — to maintain order histories and comply with applicable legal and regulatory obligations

3. Order Data Confidentiality

General Oligo treats all order and configuration data as confidential. This applies across all product lines. Specifically:

• Order data will not be disclosed to any third party except as required by law or as necessary to fulfill your order, including internal production personnel
• Order data will not be used for General Oligo’s own internal research, product development, or competitive analysis
• Order data will not be published, shared, or referenced in any external communication without your express written consent

General Oligo recognizes that NAB configuration selections — including backbone chemistry, modification type, modification density, production scale, and formulation — and Research Kit order details may reflect sensitive or proprietary research directions. These are treated with the highest level of confidentiality within our organization, with access limited strictly to personnel required to fulfill your order.

General Oligo’s confidentiality commitment with respect to your order data survives completion or cancellation of your order for a period of three (3) years.

4. Data Sharing

General Oligo does not share your personal information or order data with any third party for marketing, advertising, or commercial purposes. Limited data sharing occurs only in the following circumstances:

• Payment processing — payment transactions are processed directly by Stripe, our third-party payment processor. General Oligo transmits only the information necessary to complete your transaction and does not store your full payment card details.
• Shipping — your name and shipping address will be shared with UPS or such other carrier as may be used to deliver your order.
• Production partners — in the event General Oligo engages a contracted manufacturing partner to fulfill an order, that partner will receive only the configuration and fulfillment information necessary to produce and ship your order, and will be subject to equivalent confidentiality obligations.
• Legal obligations — we may disclose information if required by law, court order, or governmental authority, or to protect the rights, property, or safety of General Oligo, our customers, or the public.
• Business transfers — in the event of a merger, acquisition, or sale of all or substantially all of General Oligo’s assets, your information may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and the acquiring entity will be bound by this policy or provide you with notice of any material changes.

5. Data Retention

General Oligo retains customer data for as long as necessary to fulfill the purposes described in this policy, subject to the following guidelines:

• Customer account and contact information is retained for the duration of the customer relationship and for a minimum of three (3) years following the last order, to support customer service, quality assurance, and dispute resolution.
• NAB order and configuration data is retained indefinitely to support quality control, regulatory compliance, production improvement, and response to any claims or disputes arising from an order.
• Research Kit and Accessory order data is retained for a minimum of three (3) years following the order date to support customer service, quality assurance, and dispute resolution.
• Payment confirmation records are retained as provided by Stripe in accordance with their data retention policies. General Oligo retains only order amount, confirmation status, and transaction identifiers.

If you would like to request access to, correction of, or deletion of your personal data, please contact us at info@generaloligo.com. We will respond to all such requests within 30 days and in accordance with applicable law. Please note that certain records — including NAB order and configuration data — may be required to be retained regardless of a deletion request to satisfy legal, regulatory, or quality assurance obligations.

6. Data Security

General Oligo takes reasonable technical and organizational measures to protect your personal information and order data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Secure transmission of all data over HTTPS encryption
• Access controls limiting data access to authorized General Oligo personnel only, on a need-to-know basis
• Secure storage of customer account and order data on protected servers with restricted access
• Session security controls and authentication protections on all General Oligo ordering platforms
• Payment data is processed by Stripe, which maintains PCI DSS compliance. General Oligo does not store full payment card details on its systems.

No method of data transmission or storage is completely secure. While we strive to protect your information using industry-standard practices, we cannot guarantee absolute security.

In the event of a data breach that affects your personal information, General Oligo will notify affected customers as required by applicable law, and in no event later than 60 days following discovery of the breach unless prohibited by law enforcement. We will provide you with information about the nature of the breach, the data affected, and steps we are taking in response.

7. Email Communications

By creating an account or placing an order, you consent to receive transactional emails from General Oligo, including:

• Account registration confirmation and approval notifications
• Order confirmation following successful payment
• Production status updates
• Shipping notifications and tracking information
• Certificate of Analysis delivery
• Follow-up communications required to complete or support your order, including quality inquiries or delivery confirmation

These transactional emails are necessary to fulfill your order and maintain your account and cannot be opted out of while your account remains active. If you wish to close your account or update your communication preferences, please contact us at info@generaloligo.com.

General Oligo does not currently send marketing or promotional emails. If we introduce a marketing email program in the future, existing customers will not be automatically enrolled and will be given the opportunity to opt in separately. This policy will be updated accordingly.

8. Your Rights

Depending on your location, you may have certain rights with respect to your personal data. General Oligo will honor the following rights to the extent required by applicable law:

• Access — you may request a copy of the personal information General Oligo holds about you
• Correction — you may request correction of inaccurate or incomplete personal information
• Deletion — you may request deletion of your personal information, subject to General Oligo’s legal and regulatory retention obligations as described in Section 5
• Portability — you may request that we provide your personal data in a commonly used, machine-readable format where technically feasible
• Restriction — you may request that we restrict processing of your personal data in certain circumstances

To exercise any of these rights, please contact us at info@generaloligo.com with the subject line “Data Rights Request.” General Oligo may require reasonable verification of your identity before fulfilling any data request. We will respond to all verified requests within 30 days in accordance with applicable law.

If you are located in the European Union or United Kingdom, you may also have the right to lodge a complaint with your local data protection supervisory authority if you believe your rights have not been respected.

If you are located in California, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected, the right to opt out of the sale of personal information (General Oligo does not sell personal information), and the right to non-discrimination for exercising your privacy rights.

9. Changes to This Policy

General Oligo reserves the right to update this Data Usage Policy at any time. Updates will be posted to this page with a revised effective date.

For material changes — including changes to what information we collect, how we use it, with whom we share it, or how long we retain it — General Oligo will provide at least 30 days advance notice by email to the address associated with your account before the changes take effect. Your continued use of the Configurator following the effective date of any update constitutes your acceptance of the revised policy.

For non-material changes such as corrections, clarifications, or formatting updates, the revised policy will be posted without advance notice.

We encourage you to review this policy periodically. If you do not agree with any material change to this policy, you may close your account by contacting us at info@generaloligo.com prior to the effective date of the change.

10. Contact

For questions, concerns, or requests related to this Data Usage Policy, please contact us at:

For general inquiries, please use the subject line: “Data Usage Policy Inquiry”

For formal data rights requests under Section 8, please use the subject line: “Data Rights Request”

General Oligo will make reasonable efforts to respond to general inquiries within 3 business days and to formal data rights requests within 30 days, in accordance with applicable law.