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OXFORD BIOLABS' Code of Conduct on DATA PRIVACY and DATA PROTECTION
i) Oxford Biolabs Ltd, Oxford Biolabs Deutschland GmbH and Oxford Biolabs USA LLC as data controllers, and
ii) Oxford Biolabs Ukraine LLC and Keilwert Services LLC as a data processors for the data controllers.
Article 1 – Scope, Applicability and Implementation Scope
Article 2 – Purposes for processing personal data
Legitimate Business Purposes
2.1 Personal data shall be collected, used, transferred or otherwise processed for one or more of the following legitimate business purposes (“Business Purpose”):
(i) Purposes necessary to conduct Oxford Biolabs business.
This addresses processing necessary for activities such as:
(a) conclusion and execution of agreements with Customers, Suppliers and Business Partners;
(b) to record and financially settle delivered services, products and materials to and from Oxford Biolabs;
(c) marketing, sales, and promotions;
(d) account management;
(e) customer service;
(f) finance and accounting;
(g) research and development;
(i) internal management and control;
(j) external communications;
(k) government and legal affairs;
(l) alliances, ventures, mergers, acquisitions, and divestitures; or
(m) intellectual property and standards management
However, Oxford Biolabs does not store payment card numbers on its servers. Payment card numbers are submitted to payment card authorisation services, which provide Oxford Biolabs with validation information only. Oxford Biolabs does not have access to your personal financial data.
(ii) Business process execution and internal management.
This addresses processing necessary for activities such as managing company assets, conducting internal audits and investigations, and implementing business controls;
(iii) Health, safety and security.
This addresses processing necessary for activities such as those involving health and safety, the protection of Oxford Biolabs and employee assets, and the authentication of Customer, Supplier or Business Partner status and access rights;
(iv) Compliance with legal obligations.
This addresses processing necessary for compliance with a legal obligation to which Oxford Biolabs is subject; or
(v) Vital interests.
This addresses processing necessary to protect a vital interest of an individual.
2.2 If none of the criteria listed in Article 2.1 applies, or if consent is required by applicable local law, Oxford Biolabs shall obtain explicit consent from the individual before processing their personal data. When seeking consent, Oxford Biolabs shall inform the individual of:
(i) the purposes of the processing for which consent is requested; and
(ii) any other relevant details to seek to ensure fair processing.
Oxford Biolabs shall record each consent provided by individuals and acknowledge the consent through e-mail.
However, if the processing is reasonably necessary to address a direct request of the individual, the individual’s consent shall be implied.
Denial or withdrawal of consent
2.3 The individual may deny or withdraw consent at any time. Processing will be discontinued unless Oxford Biolabs has taken action that relies upon the previously provided consent. In such case Oxford Biolabs will discontinue processing as soon as reasonably practical.
2.4 Oxford Biolabs does not seek to nor knowingly form relationships with minors (individuals under 18 years old). When seeking explicit consent from an individual, this consent shall include acknowledgement that the individual is 18 years old or over. In the event that Oxford Biolabs subsequently learns that an individual in its databases are under 18, any consent provided by that individual will be deemed to have been withdrawn, personal data deleted to the maximum extent allowed under applicable law, and a block placed on that individual from any further trading relationship.
Article 3 – Processing of personal data for supplementary purposes
3.1 Generally, and unless explicit consent has been provided by an individual, personal data shall be initially processed only for the purposes for which it was originally collected. However, personal data may further be processed for a Legitimate Business Purpose (Article 2.1 above) of Oxford Biolabs for the following supplementary processes:
(i) transferring the personal data to an archive, under statutory documentation retention requirements;
(ii) conducting internal audits or investigations;
(iii) implementing business controls;
(iv) conducting statistical, historical or scientific research as required for the business operations of Oxford Biolabs;
(v) preparing for or engaging in dispute resolution;
(vi) in pursuit of a legal case requiring the use of relevant personal data;
(vii) managing insurance issues;
3.2 If an employee is in any doubt whether a process is a supplementary process, they shall consult the Data Protection Officer.
Article 4 – Purposes for processing Sensitive Data
Purposes for processing Sensitive Data
4.1 Oxford Biolabs shall process Sensitive Data only to the extent necessary to serve an applicable Business Purpose. Sensitive Data may be processed under one or more of the following circumstances:
(i) where the individual has explicitly consented to the processing, unless the consent may not be relied upon under applicable local law;
(ii) where processing Sensitive Data is a necessary part of providing services to the individual;
(iii) where Sensitive Data is processed in connection with, and as a necessary part of, the purchase or use by an individual of a Oxford Biolabs product or service;
(iv) where the individual is voluntarily participating in a research project or product test;
(v) as required by or allowed under applicable local law;
(vi) to establish, exercise or defend a legal claim;
(vii) only in respect of racial or ethnic data: for the authentication of Customer, Supplier or Business Partner. Oxford Biolabs may process photos and video images (in some countries photo and video images of individuals qualify as racial or ethnic data);
(vii) to prevent, detect or prosecute (including cooperating with public authorities) suspected fraud, contract breaches, violations of law, or other breaches of the terms of access to Oxford Biolabs sites or assets;
(ix) to protect a vital interest of an individual, but only where it is impossible to obtain the individual’s consent first; or
(x) where necessary to comply with an obligation of international public law (e.g. treaties).
Denial or withdrawal of consent
4.2 The information requirements of Article 2.2 and Article 2.3 also apply to the granting, denial or withdrawal of consent.
Prior Authorization of Data Protection Officer
4.3 Where Sensitive Data is processed based on a requirement of law other than the local law applicable to the processing, or based on the consent of the individual, the processing requires the prior approval of the Data Protection Officer.
Use of Sensitive Data for supplementary purposes
4.4 Sensitive Data may be processed for supplementary purposes only in accordance with Article 3.
Article 5 – Quantity and Quality of personal data
No excessive data
5.1 Oxford Biolabs shall restrict the processing of personal data to that data which is reasonably adequate for and relevant to the applicable Business Purpose. Oxford Biolabs shall take reasonable steps to securely delete or destroy personal data that is not required for the applicable Business Purpose.
5.2 Oxford Biolabs generally shall retain personal data only:
(i) for the period required to serve the applicable Business Purpose;
(ii) to the extent reasonably necessary to comply with an applicable legal requirement; or (iii) as part of documentation required under statutory Documentation Retention requirements
Oxford Biolabs may specify (e.g., in a sub-policy, notice or records retention schedule) a time period for which certain categories of personal data will be kept.
End of retention period
5.3 Promptly after the applicable retention period has ended, the Data Protection Officer shall direct that the personal data be:
(i) securely deleted or destroyed;
(ii) de-identified; or
(iii) transferred to an archive (unless this is prohibited by applicable local law or an applicable records retention schedule).
Quality of personal data
5.4 Personal data should be accurate, complete and kept up-to-date to the extent reasonably necessary for the applicable Business Purpose.
Informing Oxford Biolabs
5.5 Oxford Biolabs will undertake reasonable efforts to ensure that personal data is accurate, complete and up-to-date. However, it is the final responsibility of the individual to inform Oxford Biolabs if their personal data is inaccurate, incomplete or outdated and Oxford Biolabs shall rectify the data in accordance with Article 7.
Article 6 – Informing the individual Information to the individual for each processing
6.1 Oxford Biolabs shall inform the individual concerning:
(i) the Business Purposes for which personal data is processed;
(ii) which member of the Oxford Biolabs Group of Companies is responsible for the processing (as data controller); and
(iii) other relevant information (e.g., the nature and categories of the processed personal data, the categories of Third Parties to which the personal data are disclosed, if any, and how the individual can exercise their rights).
(i) the contact details of the Oxford Biolabs, as data controller, its customer service department and the Data Protection Officer
(ii) the Business Purpose of the processing for which the personal data is intended and the consequences of having incomplete personal data
(iii) the period for which the personal data will be stored or the criteria used to determine that period
(iv) the existence of the individual’s rights (see Article 7 below)
(v) the right to lodge a complaint (see Article 17 below)
(viii) the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
(x) a statement that personal data will not be transferred, sold, leased or rented to a Third Party data controller, except as required under applicable law.
Personal data not obtained from the individual
6.2 To the extent required by applicable law, where personal data has not been obtained directly from the individual, Oxford Biolabs shall provide the individual with information as required by Article 6.1, as well as:
(i) which Oxford Biolabs company was in receipt of this data;
(ii) the source of that personal data, including if publicly accessible;
(iii) the categories of personal data concerned;
This communication shall occur no later than the time the personal data is recorded in a Oxford Biolabs database.
6.3 The requirements of Article 6.2 may be set aside if:
(i) it is impossible or would involve a disproportionate effort to inform the individual; or (ii) such provision of information would result in disproportionate cost.
Article 7 – Rights of individuals
Rights of individuals
7.2 To access, rectify, delete, or block personal data or to object to the processing, the individual should send their request or objection to the contact person or contact point indicated in the relevant Data Protection Statement. If no contact person or contact point is indicated, the individual may send their request or objection to Oxford Biolabs through the contact section of the relevant Oxford Biolabs website, or they may contact the Data Protection Officer. Prior to fulfilling the request of the individual, Oxford Biolabs may require the individual to:
(i) specify the type of personal data in question;
(ii) specify, to the extent reasonably possible, the data system in which the personal data likely is stored;
(iii) specify the circumstances in which Oxford Biolabs obtained the personal data;
(iv) show proof of their identity; and
7.3 Without undue delay, and in any case within four weeks of Oxford Biolabs receiving the request or the objection, the Data Protection Officer shall inform the individual in writing either:
(i) of Oxford Biolabs position with regard to the request or the objection and any action Oxford Biolabs has taken or will take in response, or
(ii) the ultimate date on which they will be informed of Oxford Biolabs position, which date shall be no later than eight weeks thereafter.
7.4 An individual may file a complaint in accordance with Article 17 if:
(i) the response to the request or the objection is unsatisfactory to the individual (e.g., the request is denied); or
(ii) the individual has not received a response as required by Article 7.3.
Denial of requests
7.5 Oxford Biolabs may deny an individual’s request or objection if:
(i) the request or objection does not meet the requirements of Articles 7.1 and 7.2;
(ii) the request or objection is not sufficiently specific;
(iii) the identity of the relevant individual cannot be established by reasonable means; or (iv) the request or objection is made within an unreasonable time interval of a prior request or objection or otherwise; or constitutes an abuse of rights, for instance because of its repetitive character. A time interval between requests of six months or less shall generally be deemed to be an unreasonable time interval. Before denying a request or objection, employees shall seek the advice of the Data Protection Officer.
Article 8 – Security Requirements
8.1 Oxford Biolabs shall take appropriate commercially reasonable technical, physical and organisational measures to protect personal data from misuse or accidental, unlawful or unauthorised destruction, loss, alteration, disclosure, acquisition or access.
8.2 Employees shall be provided access to personal data only to the extent necessary to serve the applicable Business Purpose and to perform their job.
8.3 Employees who access personal data shall meet their confidentiality obligations as specified by their contract of employment, and other Oxford Biolabs policies and procedures.
Article 9 – Direct Marketing
Explicit consent for direct marketing
9.1 To the extent required by applicable law, when processing personal data for the purpose of making direct marketing communications, Oxford Biolabs will obtain their explicit consent of the targeted individual. In every subsequent direct marketing communication that is made to the individual, the individual shall be offered the opportunity to withdraw their consent (opt-out) of further marketing communication.
Objection to marketing
9.2 If the individual objects to receiving marketing communications from Oxford Biolabs, or withdraws their consent to receive such materials, Oxford Biolabs will take steps to refrain from sending further marketing materials, and any other material not connected with a Business Purpose, as specifically requested by the individual. Oxford Biolabs will do so within the time period required by applicable law.
Article 10 – Automated Decision Making
10.1 Automated tools may be used to make decisions about individuals but decisions may not be based solely on the results provided by the automated tool. This restriction does not apply if:
(i) explicit consent has been provided by the individual to the contrary;
(i) the use of automated tools is required or authorised by law; or
(ii) the decision is made by Oxford Biolabs for purposes of entering into or performing a contract provided that:
(a) the underlying request leading to a decision by Oxford Biolabs was made by the individual (e.g., where automated tools are used to qualify contest entries or process requests from Customers); or
(b) suitable measures are taken to safeguard the legitimate interests of the individual (e.g., the individual has been provided with an opportunity to express their point of view).
Article 11 – Transfer of personal data to Third Parties
Transfer to Third Parties
11.1 This Article sets forth requirements concerning the transfer of personal data from Oxford Biolabs to a Third Party. Note that a transfer of personal data includes situations in which:
(i) Oxford Biolabs discloses personal data to Third Parties (e.g., in the context of corporate due diligence); or
(ii) Oxford Biolabs provides remote access to personal data to a Third Party.
Third Party Data Controllers and Third Party Data Processors
11.2 There are two categories of Third Parties:
(i) Third Party Data Processors: these are Third Parties that process personal data solely on behalf of Oxford Biolabs and at its direction (e.g., providers that host accounting software, order management software, customer relationship management software, payment software); and
(ii) Third Party Data Controllers: these are Third Parties that process personal data and determine the purposes and means of the processing.
Transfer for applicable Business Purposes only
11.3 Oxford Biolabs shall transfer personal data to a Third Party only as necessary to serve the Business Purpose for which the personal data is processed (including supplementary purposes as per Article 3 or purposes for which the individual has provided consent in accordance with Article 2).
Third Party Data Controllers
11.4 Oxford Biolabs shall not transfer, sell, lease, or rent personal data to a Third Party data controller except as required under applicable law.
Third Party Data Processors
11.5 Third Party data processors may process personal data only if the third party data processor has a written contract with Oxford Biolabs. The contract shall include provisions addressing the following:
(i) the Third Party data processor shall process personal data only in accordance with Oxford Biolabs instructions and for the purposes authorised by Oxford Biolabs;
(ii) the Third Party data processor shall keep the personal data confidential;
(iii) the Third Party data processor shall take appropriate technical, physical and organizational security measures to protect the personal data; and
(iv) the Third Party data processor shall not permit subcontractors to Process personal data in connection with its obligations to Oxford Biolabs without the prior written consent of Oxford Biolabs. Furthermore, contracts with Third Party data processors shall include, as appropriate, provisions addressing the following:
(v) Oxford Biolabs has the right to review the security measures taken by the Third Party data processor and the third party data processor shall submit its relevant data processing facilities to audits and inspections by Oxford Biolabs or any relevant government authority; and
(vi) the Third Party data processor shall promptly inform Oxford Biolabs of any Data Breach involving personal data, without undue delay.
All such contracts shall be drafted in consultation with the Data Protection Officer.
Transfer of personal data to a Country with Absence of Adequacy
11.6 This Article sets forth additional rules for the transfer of personal data to a Third Party located in a country that is not considered by the EU Commission to provide an ‘adequate level of protection’ for personal data (Country with Absence of Adequacy). Personal data may be transferred to a Third Party located in a Country with Absence of Adequacy only if:
(ii) the Third Party has implemented binding corporate rules or a similar transfer control mechanism which provide adequate safeguards as required under applicable law;
(iii) the transfer is necessary for the performance of a contract with the Customer, Supplier or Business Partner or to take necessary steps at the request of the Customer, Supplier or Business Partner prior to entering into a contract;
(iv) the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between Oxford Biolabs and a Third Party (e.g. in case of recalls);
(v) the transfer is necessary to protect a vital interest of the individual;
(vi) the transfer is necessary for the establishment, exercise or defense of a legal claim;
(vii) the transfer is required by any applicable law to which the relevant Oxford Biolabs Group Company is subject; or
(viii) the individual has consented to such transfer.
To the extent permitted by law, items (vii) and (viii) above require the prior approval of the Data Protection Officer.
Consent for transfer
11.7 When seeking consent pursuant to Article 11.6 (viii), the individual shall be first provided with the following information:
(i) the purpose of the transfer;
(ii) the identity of the transferring member of the Oxford Biolabs Group of Companies;
(iii) the identity or categories of Third Parties to which the personal data will be transferred;
(iv) the categories of personal data that will be transferred;
(v) the country to which the personal data will be transferred; and
(vi) the fact that the personal data will be transferred to a Country with Absence of Adequacy.
Transfers between NonAdequate Countries
11.8 This Article sets forth rules for transfers of personal data that was collected in connection with the activities of a member of the Oxford Biolabs Group of Companies located in a Country with Absence of Adequacy to a Third Party also located in a Country with Absence of Adequacy. In addition to the grounds listed in Article 11.6, these transfers are permitted if they are:
(i) necessary for compliance with a legal obligation to which the relevant member of the Oxford Biolabs Group of Companies is subject;
(ii) necessary to serve the public interest; or
(iii) necessary to satisfy a Business Purpose of Oxford Biolabs.
Article 12 – Overriding Interests
(i) protect the legitimate business interests of Oxford Biolabs including:
(a) the health, security or safety of individuals;
(b) Oxford Biolabs intellectual property rights, trade secrets or reputation;
(c) the continuity of Oxford Biolabs business operations;
(d) the preservation of confidentiality in a proposed sale, merger or acquisition of a business; or
(e) the involvement of trusted advisors or consultants for business, legal, tax, or insurance purposes.
(ii) prevent or investigate suspected or actual violations of:
(a) law (including cooperating with law enforcement);
(b) contracts; or
(c) or Oxford Biolabs policies; or
(iii) otherwise protect or defend the rights or freedoms of Oxford Biolabs, its employees or other persons.
Exceptions in the event of Overriding Interests
12.2 If an Overriding Interest exists, one or more of the following obligations of Oxford Biolabs or rights of the individual may be set aside:
(i) Article 3.1 (Use of personal data for a supplementary purpose);
(ii) Article 6.1 (Information to the individual);
(iii) Article 7.1 (Rights of individuals);
(iv) Article 8 (Data Security); and
(v) Articles 11.4, 11.5 and 11.6 (i) (Third Party data controller contracts, Third Party data processor contracts, Transfer of personal data to a Country with Absence of Adequacy).
12.3 The requirements of Article 4.1 (Sensitive Data) may be set aside only for the Overriding Interests listed in this Article 12.1(i)(a), (c) and (e), (ii) and (iii).
Consultation with the Data Protection Officer
12.4 Setting aside obligations of Oxford Biolabs or rights of individuals based on an Overriding Interest requires the prior consultation of the Data Protection Officer.
Information to the individual
12.5 Upon request of the individual, Oxford Biolabs shall inform the individual of the Overriding Interest that led to the setting aside of Oxford Biolabs obligations or the rights of the individual, unless the particular Overriding Interest sets aside the requirements of Articles 6.2 or 7.2, in which case the request shall be denied.
Article 13 – Supervision and compliance
Data Protection Officer
13.1 Oxford Biolabs shall appoint a Data Protection Officer who is responsible for:
(ii) providing weekly updates to the Managing Director of Oxford Biolabs Ltd and quarterly reports to the Board of Directors of Oxford Biolabs Ltd on data protection risks and compliance issues; and
(iii) coordinating official investigations or inquiries into the processing of personal data by a public authority.
(iv) the development of the policies, procedures and system information (as required by Article 14);
(vi) planning training and awareness programmes (Article 15);
(viii) collecting, investigating and resolving privacy inquiries, concerns and complaints; and
(x) informing the individual in writing (as required by Article 7.4);
(xi) directing that personal data is securely deleted or destroyed, de-identified or transferred to an Archive promptly after the end of the retention period (as required by Article 5.3);
(xiii) undertaking Data Protection Impact Assessments; and
The contact details of the Data Protection Officer shall be published on each Oxford Biolabs internet website.
Default Data Protection Officer
Article 14 – Policies and procedures
Policies and procedures
14.2 Oxford Biolabs shall maintain readily available information regarding the structure and functioning of all systems and processes that process personal data (e.g. inventory of systems and processes, privacy impact assessments).
Article 15 – Training
Article 16 – Monitoring compliance
Applicable professional standards of independence, integrity and confidentiality shall be observed when conducting an audit. The results of any audit shall in all cases be presented to the Board of Directors at the following Board Meeting.
16.2 The Data Protection Officer shall produce an annual Customer, Supplier and Business Partner privacy report for consideration at the Board Meeting immediately following the 31st January each year.
Article 17 – Complaint procedure
Complaint to Data Protection Officer
(a) when necessary, advise the organization on the appropriate measures for compliance; and
(b) when measures are undertaken, monitor the steps designed to achieve compliance until all compliance measures are completed.
The Data Protection Officer may consult with any government authority having jurisdiction over a particular matter about the measures to be taken.
Reply to the individual
17.2 Within four weeks of Oxford Biolabs receiving a complaint, the Data Protection Officer shall inform the individual in writing either:
(i) of Oxford Biolabs position with regard to the complaint and any action Oxford Biolabs has taken or will take in response; or
(ii) the ultimate date on which she will be informed of Oxford Biolabs position, which date shall be no later than twelve weeks thereafter.
Complaint to the Managing Director of Oxford Biolabs Ltd
17.3 An individual may file a complaint with the Managing Director of Oxford Biolabs if:
(i) the resolution of the complaint by the Data Protection Officer is unsatisfactory to the individual (e.g., the complaint is rejected);
(ii) the individual has not received a response as required by Article 17.2; or
(iii) the time period provided to the individual pursuant to Article 17.2 is, in light of the relevant circumstances, unreasonably long and the individual has objected but has not been provided with a shorter, more reasonable time period in which they will receive a response.
17.4 The operation of the Complaints procedure outlined in this Article shall not effect the statutory rights of the individual, including the right of complaint to the relevant supervisory authority.
Article 18 – Legal issues
Local law and jurisdiction
18.1 Any processing by Oxford Biolabs of personal data shall remain to be governed by applicable local law. Individuals keep any rights and remedies they may have under applicable local law. Local public authorities having jurisdiction over the relevant matters maintain their authority.
Specific provision when Data Protection Authorities in EEA have jurisdiction under local law
Available remedies and burden of proof
Article 19 – Sanctions for non-compliance
20.2 Any amendment shall enter into force after it has been approved and published on the Oxford Biolabs intranet.
ANNEX 1 Definitions
ARCHIVE shall mean a collection of personal data that is no longer necessary to achieve the purposes for which the personal data originally were collected or that are no longer used for general business activities, but are used only for historical, scientific or statistical purposes, dispute resolution, investigations or general archiving purposes. An archive includes any data set that is subject to appropriately enhanced security and has restricted access.
BUSINESS CONTACT INFORMATION shall mean personal information typically found on a business card that is used by an individual in the conduct of her employment.
BUSINESS PARTNER shall mean any (a) individual or (b) individual associated with an entity, other than a Customer or Supplier, which has a business relationship or strategic alliance with Oxford Biolabs (such as a joint marketing partner, joint venture or joint development partner).
BUSINESS PURPOSE shall mean a purpose for processing personal data as specified in Article 2 or 3 or for processing Sensitive Data as specified in Article 4. .
COUNTRY shall mean each country in which a group company is established.
COUNTRY WITH ABSENCE OF ADEQUACY shall mean a country that is deemed not to provide an “adequate” level of data protection, under the determination of the EU Commission.
CUSTOMER shall mean any (a) individual or (b) individual associated with an entity, which purchases or may purchase a Oxford Biolabs product or service.
DATA BREACH shall mean any actual or suspected theft, or unauthorized processing, loss, use, disclosure, or acquisition of, or access to, any data.
DATA CONTROLLER shall mean the entity or natural person which alone or jointly with others determines the purposes and means of the processing of personal data.
DATA PROCESSOR shall mean the entity or natural person which Processes personal data on behalf of the Data Controller.
EEA (or European Economic Area) shall mean all Member States of the European Union, plus Norway, Iceland and Liechtenstein.
EMPLOYEE shall mean an employee, job applicant or former employee of Oxford Biolabs.
GENERAL DATA PROTECTION REGULATION shall mean the Regulation 2016/679 of the European Commission on the protection of individuals with regard to the processing of personal data and on the free movement of such data.
OVERRIDING INTEREST shall mean a pressing legitimate need that under specific circumstances outweighs the interest of the individual. personal data personal data shall mean any information relating to an identified or identifiable individual where the individual is associated with a Oxford Biolabs Customer, Supplier or Business Partner.
OXFORD BIOLABS shall mean the Oxford Biolabs Group of Companies.
OXFORD BIOLABS GROUP OF COMPANIES shall mean Oxford Biolabs Ltd, Oxford Biolabs Deutschland GmbH, Oxford Biolabs USA LLC, Oxford Biolabs Ukraine LLC, Keilwert Services LLC, and any company or legal entity of which one of these companies, directly or indirectly owns more than 50% of the issued share capital, has 50% or more of the voting power at general meetings of shareholders, has the power to appoint a majority of the directors, or otherwise directs the activities of such other legal entity;
SENSITIVE DATA shall mean personal data that reveals an individual’s racial or ethnic origin, political opinions, or membership in political parties or similar organisations, religious or philosophical beliefs, membership in a professional or trade organisation or union, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning physical or mental health or mental health including any opinion thereof, addictions, criminal offences, criminal records, proceedings with regard to criminal or unlawful behaviour, social security numbers issued by the government or similar identifying references, or data concerning a natural person’s sex life or sexual orientation.
SUPPLIER shall mean any (a) individual or (b) individual associated with an entity, which provides goods or services to Oxford Biolabs (such as an agent, consultant or vendor).
THIRD PARTY shall mean any person or entity (e.g., an organisations or government authority) that is not a member of the Oxford Biolabs Group of Companies.
Terms & Conditions
Updated on: 16th February 2017
Terms of Service
Responsibility of Contributors
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Disclaimer of Warranties
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No persons associated with Oxford Biolabs will be held liable or responsible for any form of use or misuse of any product, whether the information was gathered from this website or not.
YOU SHOULD CONSULT WITH A HEALTHCARE PROFESSIONAL BEFORE STARTING ANY DIET, EXERCISE, AND SUPPLEMENT MEDICATION PROGRAM.
Oxford Biolabs Ltd (“Oxford Biolabs” – the company behind TRX2®) is committed to ensuring satisfaction for all customers who purchase its products.
Oxford Biolabs Returns Policy
For non-USA customers
(All countries excluding the USA):
Oxford Biolabs Ltd.℅ Mailcom AGLise-Meitner-Str.482216 MaisachGermany
Oxford Biolabs Ltd.
℅ PickPackDespatch Ltd
Unit 5, Mead Park
Thorpe Mead, Banbury
OX16 4RY, UK
For USA customers only:
Oxford Biolabs USA LLC
Specialty Fulfillment Center Inc
3 - 17th Avenue South
Nampa, ID 83651
Defining Returns and Cancellations
Details of the Oxford Biolabs Returns Policy
Please note: For our physical products we can only refund you for unopened and unused products. Products that have been opened or used are excluded from our refund policy. Please be advised that the breaking of a seal used on the outer packaging of our products shall be regarded as that the products have been opened.
Payouts from that sale are debited back out of the corresponding vendor and affiliate accounts.
Reasons Why a Sale May Be Refunded
Oxford Biolabs Cancellation Policy
A customer may cancel an auto-delivery programme at any time. A cancellation means that no future charges will be made to the customer’s account. The cancellation of an auto-delivery programme does not generate a refund.
Abuse of the Returns Policy
Customers requesting serial or repeated returns may be blocked from making further purchases.
Note to Oxford Biolabs Customers
The Return Policy and the Cancellation Policy are part of, and incorporated within, the Oxford Biolabs' Terms of Service. As a condition of registering with Oxford Biolabs and using the Oxford Biolabs Services, you expressly acknowledge that you have read and understood the Oxford Biolabs Returns Policy and Oxford Biolabs Cancellation Policy and you agree to be bound by the terms and conditions contained within. If at any time you disagree with the Oxford Biolabs Returns Policy and/or Oxford Biolabs Cancellation Policy or any part of it, your sole remedy is to cease all use of the Oxford Biolabs Services and terminate your account. Please note, however, that any transactions, which occurred prior to the date of such termination, shall be governed and controlled in full by the terms of this Oxford Biolabs Returns Policy and Oxford Biolabs Cancellation Policy.
Is TRX2® appropriate for children?
We don’t have any data on children, and we only knowingly sell our products to adults.
We recommend customers to consult with their personal doctor/healthcare professional about whether TRX2® is suitable for their children.
Can women experiencing hair loss/thinning use TRX2® as well as men?
Yes, TRX2® is for both women and men. You should be able to expect your first positive results after around 5 months, depending on your metabolism and individual circumstances.
We recognise that hair loss can be a very detrimental condition for many patients, for both women and men. Those who invest their time and money into our products expect results, and we do not take this responsibility lightly.
Currently, one of the most common treatments for women with androgenetic alopecia is Women’s 2% Minoxidil. Although the use of Minoxidil is widespread, there are a lot of female users who are left unsatisfied with the results they achieve. As a potassium-ion channel opener, TRX2® stimulates the same pathways as Minoxidil, and the two treatments often have a synergistic affect. Therefore, women with significant hair loss can consider using both products simultaneously.
Although we cannot guarantee that all of the hair will grow back, we are confident that TRX2® (with or without Minoxidil) will improve the current condition to a noticeable degree. Fighting hair loss requires a multi-faceted approach that stimulates the formation of new hair follicles, increases the diameter of existing follicles, and prolongs the anagen phase of hair shafts (reducing shedding and fallout).
By restoring the function of potassium-ion channels within hair follicles, TRX2® supplementation accomplishes many of these goals. Because our product uses natural ingredients and it does not rely on the elimination of androgens, it is effective in women and it is safe for long-term use.
What will future TRX2® products address?
Our researchers, along with several other members of the scientific community, have demonstrated that as people experience hair loss the function of potassium channels within hair follicles diminishes. The effect is impaired membrane potential and interrupted ion transportation across the hair follicle’s cellular membranes – resulting in shrinking follicles and thinning hair.
TRX2® Molecular Food Supplement for Hair addresses this phenomenon, but yet may be unable to restore thick, terminal hair growth to customers with severe hair loss (Norwood 5-7). Therefore, although the launch of our first products utilising our proprietary technology is extremely exciting for us, we’re not done yet. Oxford Biolabs has an ongoing programme of pre-clinical and clinical research focused towards refining our understanding of the molecular mechanisms behind hair loss and, ultimately, developing a cure.
Please refer to our TRX2® Research page for details on past and ongoing studies.
What do regulatory agencies, such as the FDA and FSA, advise with regard to evaluating and buying dietary supplements
The United States Food and Drug Administration (FDA) offers “Tips for Dietary Supplement Users” at:
Are your food supplements approved by any regulatory agency such as the FDA, the MHRA or the European Food Standard Agency?
Our food supplements are a non-prescription food supplement products. They are therefore sold in accordance with major international food directives, such as the EC (European Community) Food Supplements Directive 2002/46/EC and the Dietary Supplement Health and Education Act, passed by the United States Congress in 1994. This Act, for instance, allows marketing of dietary supplements without prior approval by the U. S. Food and Drug Administration (FDA). However, the FDA still exerts general oversight over product safety and supervises the marketing claims made for dietary supplements.
Why do you recommend taking TRX2® Molecular Food Supplement for Hair with meals?
We recommend taking TRX2 ® Molecular Food Supplement for Hair with meals as occasionally customers have reported an upset stomach when ingesting the supplement without food. TRX2 ® Molecular Food Supplement for Hair is absorbed more efficiently into the bloodstream when taken together with food.
Can we see before and after photos for TRX2® Molecular Food Supplement for Hair?
Do you have plans on selling your products outside your online store?
To get a list of physical locations that sell our products, please e-mail us at [email protected] and provide us with your city, province and country.
Should I take TRX2® Molecular Food Supplement for Hair in the morning or in the evening, when is the best time?
It doesn’t really make a difference at which time of the day you take TRX2®. However, it is important to take it together with food in order to increase the body’s absorption of the ingredients contained in TRX2®. Most customers choose to take TRX2® during breakfast. Others prefer to split up the 3 capsules across the day (e.g. 2 in the morning and 1 in the evening).
Ultimately, the best time for taking TRX2® is totally up to you and best results, depending on your metabolism, may be different from customer to customer.
What does “chronic medication” mean?
“Chronic medication” refers to any prescription drugs a customer may use. We are legally bound to advise our customers to always disclose any dietary changes to their doctor or healthcare professional when on chronic medication. This is good practice as well as in your own interest (for example if your chronic condition is connected to any dietary issues).
At what age should one start taking TRX2® Molecular Food Supplement for Hair?
TRX2® is beneficial for all age groups. We tested our supplement in a variety of patient groups, but found it was most effective for those patients with Norwood Hair Loss Patterns 1-4 (shown here: http://www.americanhairloss.org/men_hair_loss/the_norwood_scale.asp).
Young men who are just beginning to lose their hair will see minimal regrowth (because only a minimal amount of hair has been lost); however, they can expect their hair shedding to decrease and their hair volume to increase. Middle-aged men will see similar benefits, although those with very extensive hair loss (Norwood Patterns 5-7) will not be able to regrow all of their hair. Nonetheless, our product has been administered to older males with noticeable hair loss and the results have been quite good.
Can we see your clinical trials results?
All our studies are published on our website as and when they are fully conducted and analysed. For more information please refer to http://oxfordbiolabs.com/oxford-research
How many capsules per day should I take?
One bottle which contains 90 capsules will last 30 days (taking three capsules a day is the recommended quantity). It takes most patients about 5 months (5 bottles) to see results, but some patients report results in as little as three months (for others it takes longer). This discrepancy is largely dependent on a person’s metabolism and genetic predisposition.
Some customers increase the quantity to 4 capsules per day and report an improved efficacy compared to the recommended quantity. However, all our data is based on the dose of 3 capsules per day – there should be no need to increase the quantity (unless you are overweight or have a large body weight).
Some customers, especially those with a light body weight or those sensitive to one of TRX2®’s ingredients (e.g. Niacin), decrease the quantity to 2 capsules per day without compromising on efficacy.
TRX2® and hair dyes
Hair dyes, especially permanent ones, have a side effect of hair loss due to the abrasive and damaging chemical ingredients they contain, e.g. ammonia and peroxide. One of the factors is also misuse or overuse of hair dye treatments, e.g. leaving dye on too long or mixing the formula incorrectly, so following directions is important.
Semi-permanent hair dye has fewer chemicals and has no ammonia. Henna hair dye is highly recommended as a good alternative since it contains all natural ingredients.
As long as the hair follicles haven’t been damaged underneath the scalp, new healthy hair should return on its own in several months. If the follicles have been severely damaged for some reason, hair regrowth may not be possible.
Shipping & Delivery
At Oxford Biolabs we try to deliver your supplies anytime anywhere.
Save on Shipping
Because international shipping costs are high, you may prefer ordering multiple month supplies at once to save on shipping costs to take advantage of a preferential rates. Free shipping cost is available for each customer and depends on total order value. Please find the up-to-date shipping rates here:
Delivery Options and Times*
International orders are shipped no later than 1 business day after receipt and credit authorisation. We deliver using internationally reputable couriers. Average delivery time is 7 to 10 days. Oxford Biolabs issues shipping confirmation e-mails with tracking numbers to customers who provide an e-mail address.
Customers are responsible for any import taxes, customs duties, sales taxes and any other levies that may be assessed by the local country.
Customers are responsible for making sure that they are allowed to import our dietary supplement and cosmetic products. If customs in your country returns your order to us for any reason, we will refund to your credit card account the total of your purchase minus twice your shipping charge (because we must pay our carrier the same shipping charge to return the order to us), plus any other charges incurred, such as quarantine or warehousing fees assessed by Customs in your country.
Multiple Shipping Addresses
To ship to more than one address, please place a separate order for each shipping address.
If you have questions about your order, you may e-mail your enquiry to [email protected] . Customer service hours are as follows:
- 7 a.m. to 5 p.m. Pacific Time, Monday through Friday.
- UK (GMT): 7 a.m. - 5 p.m.
- Europe (CET): 8 a.m. - 6 p.m.
The TRX2 Money-Back Guarantee
Oxford Biolabs's 60-day money-back guarantee on unopened and unused product is available to all international customers. If you decide to return an order for any reason, your credit card account will be fully credited for the amount of the purchase (excluding shipping - see details under Shipping Restrictions).
E-mail [email protected] to obtain a Return Merchandise Authorisation form. Unless otherwise indicated on the invoice you received with your package, return the bottle(s) with the unused contents to:
For non-USA customers:
For USA customers only:
I need to change my shipping address…How do I do this?
If you need to change your shipping address, you can log in online through your profile and make the change yourself, but we ask that you please also e-mail us at [email protected] with your new shipping address so that we can confirm it has been updated in our system.
Can you ship my order at a faster rate to me?
Once we receive and process your order, it is then sent to our shipping department. Once they receive the order, it is shipped within 24-48 hours. The destination country will determine how long it will take for you, the customer, to receive the order.
Does “Complete” status mean the product is being shipped already?
“Complete” status means that we have already received your order.You will receive an e-mail notification once your product is already being shipped.
How long before I receive the product?
International orders are shipped no later than 1 business day after receipt and credit card authorisation. Average delivery time is 1 to 2 days (Germany and some UK), 3 to 5 days (UK), 5 to 7 days (European Union excluding Germany and UK), 7 to 10 days (United States, Japan, International – all others). Oxford Biolabs issues shipping confirmation e-mails with tracking numbers to customers who provide an email address.
Do you deliver to ALL countries?
We will deliver your supplies anytime, anywhere. We ship our products worldwide.
My tracking link doesn’t work? What do I do?
When you place an order for our products, you will receive an e-mail once your order is shipped with a tracking link so that you can follow your package right to your doorstep. If for some reason your tracking link doesn’t work, please contact us at [email protected] and we will get you an updated tracking link right away.
Shipping countries notes
Please refer below to some of the most common issues which you may experience dispatching Oxford Biolabs products to certain country:
Australia: Customs duties may apply if total value of the order exceeds AUD 1,000.
Brazil: A doctor's prescription may be required by Brazilian Customs to be presented, for Oxford Biolabs' food supplement products into the country.
Chile: Customs duties, VAT and import fees may apply if the total value of the order exceeds approximately USD 30.
China: Customs duties may apply if total value of the order exceeds CNY 1,000.
Denmark: Customs duties, VAT and import fees may apply if total value of the order exceeds DKK 1,150.
Israel: Imports with a CIF value up to USD 1,000 and with a weight up to 30 kg, are exempt from import duty. However, VAT, Purchase Tax, and Import Port Fee may apply.
Norway: Customs duties may apply if the total value of the order exceeds NOK 350.
Additional customs duties, VAT and import fees applied by customs on importation of orders, shall be borne by the customer.
If you are in any doubt, please ring customer service at one of the numbers listed at Contact Us Page, or e-mail us at [email protected]
Not finding your country?
Not finding your country in the dropdown for the shipping address during checkout?
Please be assured that we do ship to most countries worldwide. However, Oxford Biolabs operates multiple stores depending upon geographical location, so possibly you have arrived at a store which doesn't support your country's shipping address. We are sorry for the inconvenience, but we would ask you to go to the store, which supports your country, and repeat the order entry detail:
United Kingdom Store (Click here)
North American Store (Click here):
- United States;
International Store (Click here)
- Supports all other countries
Money back guarantee
How can I ask for a refund?
Our products come with an offer of a 60-day money back guarantee. If you are not completely satisfied with the product or if it is causing you any discomfort or other side effects please contact us and return your unused bottle/s. We will refund the purchased price of any unopened and unused bottles.
Auto-Delivery Supersaver Programme
If you subscribe to our Auto-Delivery Supersaver Programme, we will ship a 3-month supply of the products from one of our great package offers to you every 90 days for a combined saving of up to 32%. Also, for any of our future products, you will receive one free sample as soon as available.
Your payment will be charged every 90 days on a recurring basis (usually one day prior to shipping).
There is no minimum time commitment. To cancel or suspend shipments, simply contact Customer Service via [email protected] at least 14 days prior to your next scheduled shipping/billing date.
Please keep your credit card and shipping address current. If your information changes, including card expiration, please contact Customer Service to submit the updated information.
I want to skip/schedule next scheduled billing/shipping date
It is possible to skip your next scheduled billing/shipping date in your account. You are also welcome to contact us at [email protected] if you need to set a specific date for the next shipment.
Can I cancel my subscription?
Cancellation of your subscription (i.e. automated shipping/billing every 90 days) is possible and can be done at any time, BUT once cancelled, we will not be able to reverse it and any accrued programme benefits will be lost. The programme is designed for your comfort so that you don’t have to worry about re-ordering and ensures a constant supply of our supplements and other products.
How do I access my programme subscription?
Under the Auto-Delivery Supersaver Programme, automated shipping/billing has been setup. Furthermore, you can log in to your account (or open one in case you haven’t yet done so) to track your order status.
TRX2® and other treatments/supplements
TRX2® supplements and hair transplantation
We can’t give you an advice on when to start TRX2® supplementation after hair transplant.
Please consult with your doctor or healthcare professional.
Can I take TRX2® Molecular Food Supplement for Hair along with vitamin supplements?
Yes. In fact, Oxford Biolabs' Scientific Advisory Board recommends that healthy adults take a multivitamin in addition to their regular TRX2® supplement in order to avoid any vitamin shortages. The following vitamins and minerals have been shown to play a role in hair growth (look for them when choosing a multivitamin product):
Vitamin AVitamin EVitamin B1Vitamin B2Vitamin B3Vitamin B5Vitamin B6Vitamin B12BiotinCopperSilica / Silicious earth
When using TRX2® in combination with a multivitamin please make sure that your total daily intake does not exceed the daily recommended amount of an individual compound or vitamin. Please note that Oxford Biolabs does not promote any specific ingredient, regimen or use, and you should always consult a doctor or healthcare professional if you are not sure about something or when using TRX2® in combination with a prescription medicine or other treatment regimens.
Can I take TRX2® Molecular Food Supplement for Hair with prescription drugs?
According to the US-based Natural Medicines Comprehensive Database (NMCD), L-carnitine (one of the major ingredients in TRX2® Molecular Food Supplement for Hair capsules), can increase the effects of anticoagulants. Customers taking anticoagulants therefore should check with their healthcare professional before embarking upon a regimen that includes TRX2®. With regards to the other ingredients in TRX2® Molecular Food Supplement for Hair, the NMCD recommends that people taking anti-diabetes drugs, people consuming large quantities of alcohol and people who have frequent attacks of gout despite uricosuric therapy should consult their healthcare professional before starting TRX2® supplementation.
Of course, before taking any dietary supplement and prescription drug simultaneously, you should always consult with your doctor or healthcare professional.
If TRX2® is taken with minoxidil would it enhance results? If later I stopped with minoxidil but continued with TRX2® would hair loss start again?
Generally TRX2® is designed to be effective on its own. Hence there is no need to complement it with minoxidil. In fact all our study results are based on patients who have been only used TRX2® and no other treatment – check out http://www.trx2.com/research.
However, customers who have been using minoxidil for years and have experienced a decrease of efficacy over time have experienced enhanced efficacy once they started using TRX2® in combination with another product. Hence, there is no reason why a customer cannot use both if he or she wishes to do so. If, later on, a decision is made to stop taking minoxidil but to continue taking just TRX2®, it is unlikely that there would be negative results. (However, again we have not conducted studies on this – TRX2® is designed to be effective on its own.)
Continuous intake of TRX2® is important as it works together with your metabolism. It is not a cure. Unfortunately, there isn’t a cure yet for androgenetic alopecia (however, we are working hard on this and the majority of our research is focused on this).
Taking anti-depressants with TRX2®
We can only advise you to talk to your doctor or healthcare specialist when combining any new treatment with anti-depressants. Legally, we are not able to give advice.
Storage of food supplements
Where and how should I properly store your food supplements?
We recommend storing food supplements in a dry place and at slightly cooler temperatures, simply because this will reduce oxidation of the ingredients.
TRX2® contains L-Carnitine-L-Tartrate, which may start melting if the temperature is too hot (but this would need to be much higher than 85 Fahrenheit/30 Celsius).
Is it OK to store multiple months’ supply of food supplements in a plastic container?
We recommend keeping your supplies in the glass container provided. There are several reasons for this. The glass bottle, which we provide, protects your supplies from oxidation as well as UV light radiation. Furthermore, the glass container has an originality seal – this way you can be absolutely sure of the high quality characteristics of the product. We cannot guarantee the noted expiration date, if supplies are not kept in the glass container.
Are your food supplements safe for those who are allergic to gluten and dairy products?
As indicated, all ingredients of our food supplements are of naturally-based and produced at the highest standards of quality. The product should not contain any gluten and/or dairy fats. Also, please note that our company cannot advise you on any individual health related issues and therefore cannot take any responsibility for possible side effects when taking our food supplements. If there is any doubt, please consult your doctor and/or healthcare professional.
Are there known side effects from taking your products?
Our food supplements contain only naturally-based ingredients and therefore side effects and cross-interactions (e.g. with medications) are minimal.A very small number of customers experience an upset stomach but this can be avoided if you take our food supplements with your largest meal of the day.Please, note, we can’t advise you in medical terms. We advise consumers to consult a doctor or healthcare professional before changing their diet to include our food supplements, especially if they are on a special diet and/or take other medications (e.g. against hypertension, diabetes, etc.).
Does TRX2® cause shedding of hair?
Most patients do not report shedding as a side effect when using our supplement. Still, in some instances shedding may occur if TRX2® is being used in conjunction with treatments such as minoxidil (Rogaine). If shedding does occur, you can expect your hair to re-grow during the normal course of treatment.
Mild shedding is common when starting many new hair loss products, although it is not usually reported with TRX2®. Overall, shedding means that miniaturised hairs are starting a new cycle. If this was stimulated due to TRX2®, you can expect the hairs (when they grow back and re-cycle) to become thicker and stronger.
Shedding can be a normal part of your hair cycle (many people report increased shedding during wintertime, springtime, etc.) and should not be permanent. If your shedding becomes worse, you should always contact your personal doctor/physician.
Can TRX2® grow body hair?
Based on our studies performed to date and based on the customer experiences we have gathered so far, there shouldn’t be any extensive hair growth on body parts other than your head. The ingredients in TRX2® are suppose to act on a highly specific form of potassium ion channels (called SUR1) that are only supposed to be present in human head hair follicles, and therefore would weaken the argument that excessive hair growth occurs in body parts other than your head.
TRX2® Molecular Food Supplement for Hair – Product Information Brochure
TRX2® Molecular Food Supplement for Hair – Customer Information leaflet
TRX2® Hair Revitalising Foam – Customer Information leaflet
TRX2® Hair Revitalising Lotion – Customer Information leaflet
TRX2® Molecular Food Supplement for Hair – Multilingual Customer Information Booklet
Got another question?
Send your question to one of our Support Agents who are ready to assist you in the most convenient way.
Shipping Info and Rates
|UK (GBP)||America (USD)||Germany (EUR)||Zone 1 (EUR)||Zone 2 (EUR)||Zone 3 (EUR)||Zone 4 (EUR)|
|Autodelivery Supersaver Programme||FREE||FREE||FREE||FREE||€28.90||€32.90||€38.90|
|FREE SHIPPING (Total order value)||⩾ £75||⩾ $119||⩾ €85||⩾ €129||⩾ €260||⩾ €380||⩾ €380|
- - Worldwide shipping
- - Includes liability as per the conventions of the Universal Postal Union
- - Shipment tracking included
- - Shipping times can significantly vary between countries: Usually 3-8 days within EU and 8-15 days for most the international orders.
- United Kingdom (excluding Gibraltar)
- United States
|Bulgaria||Netherlands (except non-EU territories)|
|Denmark (except the Faroe Islands, Greenland)||Austria|
|Finland (except the Aland islands)||Portugal|
|France (except overseas departments and territories)||Romania|
|Greece (except Mount Athos)||Sweden|
|Italy (except Livigno and Campione d'Italia)||Spain (except the Canary Islands, Ceuta+Melilla)|
|Bosnia and Herzegovina||Macedonia|
All countries and territories not covered by zones Germany, UK, America, 1, 2 or 3.