PRIVACY POLICY

We take the protection of personally identifiable information (“Personal Data”) very seriously. This Privacy Notice (this “Notice”) describes how we use your Personal Data we may receive, either directly from you, or from third parties, in connection with the clinical trials (a “Trial” or the “Trials”) we sponsor. 

This Notice is applicable to you if you are a Trial patient or Trial personnel at one of our Trial sites (individually and together, “you,” “your”).

This Notice explains in general terms our commitment to comply with data privacy laws and regulations, including but not limited to the Health Insurance Portability and Accountability Act (“HIPAA”) of the United States.

Basis Of Data Collection and Processing

Before, during, and after each Trial, we will process your Personal Data for various purposes. In each case, we will rely on an appropriate lawful basis for processing your Personal Data. We will only process your sensitive Personal Data (like health and genetic data) when allowed by law.

Trial participants:

We process your Personal Data for safety and reliability purposes in order to comply with our legal obligations. 

We process your Personal Data for scientific research purposes based on our legitimate interest in conducting clinical trials and performing valuable scientific and medical research.

If we process your Personal Data for other purposes after the end of a Trial, we will do so based on your consent or our legitimate interest in conducting further research.

We will need to process data about your health in order for you to participate in a Trial. Health data is considered sensitive Personal Data (also known as a “special category” of Personal Data) and special rules apply to working with it. When we process special categories of your Personal Data, we only do so when the processing is necessary for reasons of public interest in the area of public health. Those reasons include making sure our drugs are safe and effective, and conducting our Trials safely. We also process your sensitive Personal Data based on your explicit consent.

The specific grounds on which we process your Personal Data, including your health data, may vary somewhat from the above in order to comply with the requirements of applicable local laws in jurisdictions where we sponsor Trials. If you are a patient in one of our Trials, please refer to the informed consent form you signed for more information about the legal grounds on which we process your Personal Data. If there is any conflict between any provision in this Notice and any provision in the informed consent form you signed in connection with your participation in a clinical trial we sponsor, the informed consent form shall supersede the conflicting provision in this Notice.

How We Receive Personal Data

We receive your Personal Data when:

·  you visit one of our Trial-specific websites or online portals;

·  you provide it to us, the CRO, or a Trial site directly when you complete a pre-screening questionnaire on one of our Trial-specific websites;

·  you provide it to us, the CRO, or a Trial site when you participate in a Trial;

·  your doctors or healthcare providers provide it to us; or

·  you provide it to us in your role as Trial personnel in the context of assisting in the operation of a Trial.

Purposes Of Processing

We will process Trial patients Personal Data for the purposes of:

·  determining your eligibility for a Trial;

·  conducting the Trials;

·  ensuring that each Trial therapy is safe and reliable; and

·  conducting related scientific and medical research.

We also process the Personal Data of Trial patients for the specific purposes described in the Trial information provided to Trial patients by the Trial site.

We will process Trial personnel Personal Data for the purposes of:

·  managing our relationship with Trial personnel;

·  contacting Trial personnel for planning and organizing the Trials;

·  conducting the Trials; and

·  complying with applicable laws and regulations.