Privacy Policy

Last updated October 11, 2024

1.0   OVERVIEW

1.1    Purpose

In the course of pursuing its mission of developing novel and transformative solutions to address the challenges posed by the heterogeneity of autoimmune diseases, Zura Bio Inc. and its affiliates (“Zura”) and third parties acting on its behalf collect and analyze personal information of various individuals, including:

• Employees, consultants, temporary workers, job applicants
• Patients
• Vendors/service providers
• Healthcare professionals

Zura is committed to continuing compliance with the evolving legal and regulatory standards for privacy and data protection applicable in the countries and regions in which it conducts its activities.

1.2   Scope

These Privacy Principles (the “Principles”) represent Zura’s global privacy standards and apply to all Personal Information collected, processed, shared, or used by Zura in the context of its various activities.

2.0   POLICY

2.1   Definition of Personal Information – What is Personal Information?

“Personal Information” means all information that relates to an individual (also called a Data Subject) or information that can be used to identify a person, both directly (e.g., name or photograph) and indirectly (e.g., a medical insurance number, position in a company, or a study code assigned in a clinical trial). In some countries, Personal Information may also include information such as medical device serial numbers, biological samples, health information, or internet protocol addresses. It also includes “Personal Information” or “Personal Data” as defined under applicable laws and regulations.

2.2   Who is responsible for the processing of your Personal Information?

For data processing under these Principles, the following company is the party primarily responsible under applicable data protection law also referred to as “controller” in a number of countries.

Zura Biotherapeutics, Inc.
1489 W. Warm Springs Road, Suite 110
Henderson, NV 89014
USA

Email: dpo@zurabio.com

If you are in contact with another group company, e.g. because you or your company purchase a service from this company or because you correspond directly with this other company, this company in question is in this instance the controller.

2.3   Data Subjects – Who are the Data Subjects?

“Data Subjects” has the meaning defined under applicable laws and regulations and generally means any individual person who can be identified directly or indirectly by way of an identifier of some kind e.g. name, location data, identification number, etc.

Zura processes Personal Information from the following Data Subjects fairly and lawfully:

• Employees, Contractors, Interns, & Temporary Staff Members: Zura collects and processes Personal Information to administer company processes, systems and devices, perform regular business operations, and administer human resources benefits including payments, and compliance with our legal and statutory obligations.
• Job Applicants’ Personal Information: Zura collects and processes prospective employees’ Personal Information to process job applications and to onboard incoming employees.
• Patients’ Personal Information: To enhance privacy, Data Subjects’ names and other direct identifiers are generally not attached to records or samples collected by Zura for research purposes. Instead, Data Subjects are only identified by a code.
• Vendors/Suppliers’ Personal Information: Zura interacts with various third parties vendors and service providers and needs to record certain Personal Information of their staff to be able to conduct activities together and carry out associated administrative processes.
• Healthcare Professionals Personal Information: Zura analyzes the professional profiles of doctors and other healthcare providers and professionals for the purpose of identifying potential investigators to assist in clinical and medical research on specific indications or otherwise collaborating with Zura. Zura more generally collects and processes healthcare professionals’ Personal Information for the purposes of executing specific agreements to assist in clinical or medical research and other aspects of product development.
• Website Visitors’ Data: Zura collects Personal Information about visitors to company websites through the voluntary provision of the information by the Data Subjects, e.g. when Data Subjects register with us to receive press releases or when you make contact with us through details provided on our “Contact us” page.  Through the use of cookie-based technologies, Zura may collect various data linked to virtual identities allocated to visitors when they access Zura websites. See section 2.5 and Zura Cookies Information for more details.

Please Note: Zura does not collect or maintain personally identifiable information for resale purposes, and will not share any web visitor’s personally identifiable information with any other company or organization, except to the extent that any sharing is required for the provision of services, including our website. If a web visitor does not wish to receive any email or other communication from Zura after requesting information, the web visitor may contact Zura at dpo@zurabio.com. Zura does collect and/or maintain personally identifiable information for marketing purposes such as the creation of a personalized website experience or email advertising through the purchase of opted- in email lists.

2.4   Categories of Personal Information Collected-Which Types of Personal Information?

Zura collects various types of Personal Information that may include:

• Identifiers and contact information, such as title, name, address, phone number, email address, username, photo or image
• Professional or employment-related information, including professional experience, professional qualifications, role titles, start/end dates, employment records, professional organization membership status, license number, scientific/medical society membership, medical specialization
• Educational information, such as educational background, degrees/certificates obtained, interests, and preferences
• Financial information, such as bank account or credit card details
• Demographic information, such as age, date of birth, nationality, ethnic origin, or gender
• Marital status and dependents
• Beneficiary and emergency contact information
• Performance information and compensation history
• Health-related data and other information provided in connection with the administration of human resources benefits and payroll
• Biometric data such as fingerprints or facial recognition in connection with the operation of company issued devices (phones, laptop computers)
• Other personal details included in a CV, resume, application form or cover letter or that you voluntarily provide to us
• Government identification numbers such as social insurance or other national insurance number, driver’s license number, or other identification card number
• Coded or pseudonymized patient health information including medications, medical state and history, test and imaging results and other healthcare-related information including, without limitation, Protected Health Information, from individuals or indirectly from third parties. Exceptionally such information may be identifiable for example in the case of monitoring of clinical trials, as well as product quality complaints and pharmaceutical safety data reporting
• Internet or other electronic network activity information, such as website navigational data, the name of the domain and host from which one accesses the Internet, the browser software used and operating system, the date and time Zura websites were accessed, and the Internet address of the website from which one directly linked to Zura websites

Additional Personal Information:
It is possible that we process additional Personal Information which we cannot list here conclusively. We inform you separately about the processing of such data if this is possible or we are obliged to do so.

Non-Personal Information:
Zura may also collect other information that is not Personal Information such as business, company or institutional information.

2.5   Collection and Processing of Personal Information

2.5.1   Principles – How Does Zura Collect and Use Personal Information?

Where mandated by applicable data privacy law, or where it is a matter of good practice, Zura will seek consent of Data Subjects to collect, use, and disclose their data consistent with the relevant privacy notice. Specific requirements may vary by jurisdiction and must always be followed.

As required under applicable law, Zura shall:

• Collect and use Personal Information only in instances where it has legal justification to do so.  For example, some Zura guidelines or local laws may require explicit consent of the Data Subject prior to collection of his or her Personal Information (e.g., informed consent for clinical trial participants);
• Notify Data Subjects as to how their Personal Information will be used prior to collection of such information;
• Collect only that Personal Information which is required for the specified business purpose;
• Use Personal Information only for the specific business purpose described in the applicable consent form or privacy statement or for purposes that would be reasonably anticipated by the Data Subject;
• Use Personal Information in ways that do not adversely impact the Data Subject unless such use is justified by law; and
• Anonymize or pseudonymize Personal Information where possible or appropriate.

Zura recognizes that responsible management of Personal Information is required to protect privacy rights and comply with data privacy laws and regulations.

Personal Information may be shared with among Zura affiliates, government agencies and third parties on a “need to know” basis for legitimate business reasons or as otherwise allowed or required by law.

Where required by applicable law, Zura will ensure an appropriate and lawful response to Data Subjects who exercise their individual rights to: (1) know what Personal Information is being processed and have an opportunity to correct or update it, (2) object to processing or withdraw consent to processing, as applicable, and/or (3) request correction, erasure, or blocking of their Personal Information.

Zura will take commercially reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alterations, and destruction, taking into consideration the risks involved in the processing and the nature of the Personal Information.

Zura websites may contain links to websites outside of Zura. Linked websites are not under the control of or endorsed by Zura. These Principles do not apply to linked websites outside the Zura organization. It is recommended that visitors review the privacy policy of each individually linked website.

2.5.2   Collection Methods

Zura may collect Personal Information from the following sources:

• Zura may collect Personal Information from Data Subjects directly e.g. in an employment application and related documentation, and in the course of administering regular business processes, human resources benefits and engaging service providers.
• Zura may, to the extent permitted by law, collect Personal Information from Data Subjects through various channels, including the websites, in surveys, during business events, and when delivering programs and services to various persons.
• Zura may provide opportunities to sign up to receive specific information or services and may ask for contact information (e.g., name, home/contact address, home/contact phone number or personal/contact email address), so that we can send specific information about Zura products, services and specific health conditions, with Data Subjects’ consent.
• Zura is obligated to collect certain Personal Information to comply with regulatory requirements, including information relating to potential product quality complaints and adverse effects, which may be experienced when using Zura products.
• Zura may indirectly collect information about patients’ health condition, diagnosis, and treatment from healthcare professionals, but only where the healthcare professional has obtained consent to disclose that information to Zura, as required by law.
• Zura may, to the extent permitted by law, collect various information from healthcare professionals as part of educational or research activities with healthcare professionals.
• Zura may also collect information about Data Subjects from third-party sources to supplement information received from the Data Subjects. Examples of these third-party sources include marketing vendors, authentication service providers, or background check providers. From time to time, Zura may perform research (online and offline) via surveys.
• When navigating the websites, certain passive information may also be collected.  This type of information is used for the purposes of gathering data to provide improved administration of Zura websites and to improve the quality when interacting with Zura websites.
• Zura may collect Personal Information to enable Data Subjects to use online social media resources offered either by Zura or a third party.  When using social media resources, one should take into careful consideration what Personal Information shared with others.

When using an online social media resource offered by a third-party through the Zura website, the user acknowledges that Zura may be able to access any information made public through such third-party (such as username, comments, posts and contacts) and other information the privacy settings on such third-party permit Zura to access.  Zura will comply with the terms of this Privacy Policy and the privacy policies applicable to the social media resources it uses.

2.5.3   Purpose of Data Collection

Zura and its third party service providers process the Personal Information for various purposes, in particular for the following purposes:

• Employment Applications. Process your application if you are an employee of the company and you apply for a job with us and/or process your application if you are not currently an employee of the company.
• Administration of company processes, systems, and devices. Perform regular business operations, administer human resource benefits and programs, make payments to you, including payroll, equity, and T&E reimbursement and other administrative purposes.
• Ensuring business operations and other security purposes. e.g. operation and security of IT systems and applications, support hotlines, protection of our data, secrets and assets, spam and virus filters or DLP (data loss prevention) systems, which in particular can check emails for certain search terms or the like in order to reduce the risk of sending confidential information or Personal Information to unauthorized recipients. Also, documentation of security incidents, data breaches, complaints, interactions with authorities and third parties, and other relevant events and corresponding measures that relate to or contain information about you.
• Clinical or medical/scientific research. We collect and process Personal Information for the purposes of executing specific agreements to assist in clinical or medical research and other aspects of product development and to further our research and development program.
• Identifying potential investigators. We analyze the professional profiles of doctors and other healthcare providers for the purpose of identifying potential investigators to assist in clinical and medical research on specific indications or otherwise collaborating with Zura.
• Improvement of our services and for the development of services or products.
• Providing information and services requested by a Data Subject.
• Communication purposes. i.e. to contact you and to maintain contact with you.
• Comply with our legal and regulatory obligations including pharmaceutical quality and safety data reporting obligations
• Compliance, investigations and legal proceedings. e.g. the prevention, investigation and prosecution of violations of the law, including the investigation of complaints, tips and objections, evaluation of surveillance measures and the conduct of investigations, participation in official investigations and proceedings, and the assertion, exercise or defense of legal claims.
• Other Uses. Zura may use Personal Information for which Zura has a legitimate interest, such as individual or market research, anti-fraud protection, or any other purpose disclosed.

We will inform you separately about other purposes insofar as this is possible and we are obliged to provide information.

2.5.4   Which legal justification do we use to collect your Personal Information?

The following reasons may be relied upon:

• Your consent
• That the processing is necessary for the performance of a contract or pre-contractual measures
• That the processing is necessary for the assertion or defense of legal claims or civil proceedings
• That the processing is necessary for compliance with domestic or foreign legal provisions
• That the processing is necessary for a legitimate interest in the data processing

2.6   To whom do we disclose the Personal Information?

We may disclose Personal Information to other recipients if this is necessary for the stated purposes and insofar as this is permitted by law. In particular, we disclose Personal Information to recipients of the following categories:

• Affiliated companies. Our subsidiaries, related entities, joint ventures, or other companies under common control “Affiliates”, in which case all such Affiliates must follow this Policy.
• Service providers. We use various services from third parties domestically and abroad, e.g. contract research organizations, IT service providers, maintenance and support service providers, etc. These service providers may process or access your Personal Information to the extent necessary to perform their services for us.
• Governmental authorities and official agencies. When we deem it necessary or appropriate in order to comply with laws and regulations or to verify compliance therewith, to respond to inquiries from competent authorities (e.g. in the context of a criminal investigation, in the context of regulatory submissions) or to participate in official or judicial investigations and proceedings.
• Parties to legal proceedings. e.g. opposing parties and other parties, experts, witnesses, etc., if we participate in legal proceedings or are considering participation.
• Acquisitions, mergers, dissolutions. Third parties in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. If another company acquires our company, business, or assets, that company will possess the personal data collected by us and will assume the rights and obligations regarding your personal data as described in this Policy.
• In the event of an insolvency, bankruptcy, or receivership, personal data may also be transferred as a business asset.

2.7   How long do we keep the Personal Information

We generally store your Personal Information for the duration of the contract, if applicable. Exceptions apply if longer legal retention obligations exist in individual cases, if retention is necessary for reasons of evidence or other grounds for exception exist. An exception also applies if earlier deletion is indicated (e.g. because we no longer require the data or are obliged to delete it).

For operational and security-related data, shorter retention periods usually apply. Business-related documents are retained for as long as we require them to achieve our purpose, have a sufficient business interest in retaining them or are legally obliged to do so. Zura will establish defined retention periods for the classes of Personal Information it retains pursuant to the requirements of applicable records retention and destruction policies. When the applicable retention period has expired, your Personal Information will be deleted or anonymized.

2.8   Specific Principles for Internet Users including Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

A cookie is a data file that is placed by a website operator on the hard drive of a visitor to their site. Cookies with the following functions are enabled to the computers of visitors to Zura websites for the following purposes: to allow the site to deliver the service requested by the visitor; to remember repeat visitors; to improve the user experience of the site; to allow the company to perform site analytics; and to help tailor marketing messages to the visitor based on previous browsing. Zura cookies are enabled and controlled by the Zura IT team and its service providers, which are established in the United States. The online relationship with Zura may be managed by using settings available on most internet browsers. For example, most browsers will allow a visitor to choose which cookies can be placed on his/her computer, to delete or disable cookies, and to set “Do Not Track” as a function. Please note that disabling cookies may prevent a visitor from using certain features on Zura websites. If you choose to browse in “incognito” mode, your browsing history, cookies and site data, or information entered in forms are not saved locally; this does not, however, conceal your IP address or encrypt your internet traffic.

To read more about cookies and principles for internet users please see the section below entitled: Zura Cookies Information.

Zura does not collect information through Zura websites from individuals who are known to be children under respective applicable data privacy laws, and no part of Zura online presence is directed to any children.

2.9   Transfers of Personal Information – What happens when the Personal Information goes to another country?

Zura is part of an industry that is increasingly globalized in its approach to life sciences. Personal Information will be shared across international borders as required to support global projects, particularly clinical trials and associated requirements such as safety reporting. Zura hosts Personal Information in databases in different locations throughout the world, mainly in the United States and the United Kingdom. Zura recognizes that many countries have regulations restricting the flow of Personal Information across international borders. Zura will protect the Personal Information during the transfer according to applicable laws and regulations.

2.10   What rights do you have as a resident of the EEA, UK, or Switzerland?

Right of access by the Data Subject: You have the right to obtain from us confirmation as to whether or not Personal Information concerning you is being processed, and where that is the case, to gain access to your Personal Information.

Right to rectification: You have the right to obtain from us without undue delay the rectification of inaccurate Personal Information. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure (‘right to be forgotten’): You have the right to obtain from us the erasure of Personal Information concerning you without undue delay and we have the obligation to erase Personal Information without undue delay subject to certain legal provisions.

Right to restriction of processing: You have the right to obtain from us restriction of processing subject to certain legal provisions.

Right to data portability: You have the right to receive the Personal Information concerning you, which you provided to us, in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller without hindrance from the us to which the Personal Information have been provided.

Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, including profiling. We shall no longer process the Personal Information unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of yourself or for the establishment, exercise or defense of legal claims.

Automated individual decision-making, including profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

If you would like to exercise any of these rights, please contact our Data Protection Officer (DPO) and they will supply you with the necessary request forms required to action your request.

Right to make a complaint in front of the competent authority: In case you deem it necessary to preserve your rights, you may at all times make a claim in front of the competent data protection authority.

For the EEA countries you may find these authorities under the following link: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

For UK you may go to the ICO: https://ico.org.uk

For Switzerland you may reach out to the Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch/edoeb/en/home.html

2.11   What rights do you have as California Residents?

The California Consumer Privacy Act, as amended by the California Privacy Rights Acts (CCPA), grants certain rights to California residents. For this section, Personal Information has the meaning given to it under the CCPA. To the extent the CCPA applies to our processing of your Personal Information, you are entitled to the following rights:

• Right to Know and Access: You have: (a) the right to know the categories of the Personal Information we have collected, sold, shared for cross-context behavioral advertising, or disclosed for a business purpose; the categories of sources from which the Personal Information is collected; the business or commercial purpose for collecting, selling, sharing, or disclosing Personal Information; and the categories of third parties to whom we have disclosed your Personal Information; and (b) the right to access the specific pieces of Personal Information we have collected about you.
• Right to Deletion: You have the right to request deletion of your Personal Information collected directly from you, subject to certain exceptions.
• Right to Correct: If Zura maintains inaccurate Personal Information about you, you have the right to correct such inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of the processing.
• Right to Opt-Out of Selling: You have the right to opt-out of the sale of your Personal Information to third parties. Zura does not sell Personal Information subject to the CCPA. Zura does not have actual knowledge of selling Personal Information of minors under the age of sixteen (16).
• Right to Opt-Out of Sharing for Cross-Context Behavioral Advertising: Zura does not share your Personal Information for cross-context behavioral advertising, and therefore does not provide this opt-out.
• Right to Limit Use and Disclosure of Your Sensitive Personal Information: You have the right to request that Zura limit the use and disclosure of your sensitive Personal Information. Zura does not provide this opt-out because it uses sensitive Personal Information for purposes specified in the CCPA and not for inferring characteristics about you.
• Right to Non-Discrimination: You have the right to not receive discriminatory treatment if and when you exercise your rights under the CCPA.

If you are a California resident and want to submit a request exercising your rights, please contact us at dpo@zurabio.com or by mail at the address listed below. You must provide us with sufficient information that allows us to reasonably verify who you are and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are unable to verify your identity with the information provided, we may ask you for additional pieces of information. We may also require the Individual do either of the following: (1) verify their own identity directly with the business. (2) directly confirm us that they provided the authorized agent permission to submit the request. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

Please note that we are not obligated to respond to more than two Right to Know/Access requests for the same individual’s Personal Information within a 12-month period.

California law also permits California residents to request certain information about our disclosure of Personal Information to third parties for their own direct marketing purposes during the preceding calendar year. As discussed elsewhere in this Notice, we do not currently share the Personal Information of California residents with third parties for their own direct marketing purposes. However, if you have further questions about our privacy practices and compliance with California law, please contact us as explained below.

CONTACT INFORMATION

If you have questions or comments about our privacy practices or this Notice or to request this Notice in another form, contact us at:

Zura Biotherapeutics, Inc.
1489 W. Warm Springs Road, Suite 110
Henderson, NV 89014
USA

Email: dpo@zurabio.com

2.12   Contact

All communications, queries, and requests to exercise Data Subjects’ rights (e.g., access to data) or complaints should be addressed to the attention of the Zura Data Protection Officer at dpo@zurabio.com.

We have appointed DataRep as our Data Protection Representative in the European Union so that you can contact our Representative directly in your home country. DataRep has locations in each of the 27 EU countries, Norway, and Iceland in the European Economic Area (EEA), and Switzerland. Specific details are provided below.

If you want to raise a privacy-related question to Zura, or otherwise exercise your rights in respect of your Personal Information, you may do so by contacting our Data Protection Officer listed above or contact DataRep by:

• Sending an email to datarequest@datarep.com (quoting <Zura Biotherapeutics, Inc. and Zura Bio Ltd.> in the subject line).
• Contacting us on our online webform at www.datarep.com/data-request.
• Mailing your inquiry to DataRep at the most convenient address indicated in the section below.

If you have any concerns about how DataRep will handle the personal data they may require to undertake their services, please refer to their privacy notice at www.datarep.com/privacy-policy.

Please post requests addressed to ‘DataRep’ and NOT to Zura Bio directly; communications addressed to Zura directly but at our contact locations will likely not be received.

1.0    ZURA COOKIES INFORMATION

Detailed Cookie, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising Information

Zura, as well as third parties that provide content, advertising, or other functionality on Zura services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are small data files placed on your computer, tablet, mobile phone, or other devices (collectively referred to as a “device”) that allow us to record certain pieces of information whenever you visit or interact with Zura sites, services, applications, messaging, and tools, and to recognize you across devices.

• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
• Social Media Widgets. Our Website may include social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the “Share” button or other interactive mini-programs).  These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly.  These social media features are either hosted by a Third Party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.
• Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout.

Mobile Devices

Zura may provide websites and online resources that are specifically designed to be compatible and used on mobile devices.  Zura will collect certain information that your mobile device sends when you use such websites or online resources, like a device identifier, user settings and the operating system of your device.

“Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services.  Zura does not recognize or respond to browser-initiated DNT signals.  For information about Do Not Track, visit http://www.allaboutdnt.org.

Advertising Choices

We may use certain tools offered by Third Parties, including those offered by Facebook, Inc. (“Facebook”), that enable such Third Party to collect or receive information about actions users take on: (a) our Website and elsewhere on the Internet through use of cookies, pixel tags and other storage technologies; or (b) an Zura mobile application and other mobile applications, in order to provide interest-based advertising.

Interest-based advertising is advertising that tries to make the ads you see more interesting and relevant to you based on the types of sites you visit online and other information that does not personally identify you.  Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites.  These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

For more information regarding the collection and use of such information by Facebook, please see the Facebook Data Policy, available at: https://www.facebook.com/policy.php.

You can opt out of the collection and use of your information for interest-based advertising by going to https://optout.aboutads.info or https://www.youronlinechoices.eu/ to limit collection through the Website or by configuring the settings on your mobile device to limit ad tracking through the mobile applications.

Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Websites and/or information from the advertisements on Third-Party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements.

For more specific information about the Cookies that Zura uses, please review our Cookie Policy.