Recludix Pharma Privacy Notice
Last Updated: November 29, 2021
Recludix Pharma is a venture capital funded biotechnology company engaged in small molecule drug discovery for the treatment of targeted patient populations in oncology and other therapeutic areas. This Privacy Notice is designed to help you understand how we collect, use, process, and share your personal information and to help you understand and exercise your privacy rights.
This Privacy Notice applies to personal information processed by us, including on our websites and other online or offline offerings. To make this Privacy Notice easier to read, our websites, mobile applications, and other offerings are collectively called “Services.” Recludix Pharma may provide additional privacy notices to individuals at the time we collect their personal information. For example, we provide a specific privacy notice to participants that describes our privacy practices in connection with conducting clinical trials or when you submit your information for recruitment to one of our clinical trials. Such notice will govern our use of your personal information related to the clinical trial.
2. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. For example, we may collect different information depending on whether you are a clinical trial participant, healthcare professional, patient advocate, or visitor to our website. We collect information that you provide to us, information we obtain automatically or through non-automatic methods provided that it is part of the data recording system when you use our Services, and information from other sources such as third-party services and organizations, as described below.
A. Information You Provide to Us Directly.
We may collect the following personal information that you provide to us.
- Account Creation. If you are a consumer, patient, health care professional or other person who engages with our Services or creates an account on our website, we may collect information, such as name, email address, and username.
- Healthcare Professionals and Key Opinion Leaders. If you are a healthcare professional or Key Opinion Leader, we may collect certain information such as your professional contact information, credential and institutional affiliations information, information about our programs and activities in which you have participated, our interactions with you, published papers, your photograph, and/or prescribing of our products and information in any agreements executed with us.
- Enrollment and Clinical Trial Referral Information. When you enroll in our Services, such as our patient support programs or if you request to be matched to one of our clinical trial sites through one of our referral websites, we may collect information such as your name, email address, phone number, physical address, date of birth, and relevant information about your medical history.
- Regulatory Information. We are also obligated to collect certain personal information to comply with regulatory requirements, including information relating to any adverse effects you may have experienced when using our products. We collect such information only where you have provided your consent to disclose that information to us, as required by law.
- Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, apply for a job, or otherwise communicate with us.
- Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
- Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
We may collect personal information automatically when you use our Services:
- Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
- Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
- Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
- Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
- Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
- Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
Analytics. may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
C. Information Collected from Other Sources
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you are a Healthcare Professional, we may collect information such as hospital affiliation, license information, areas of interest, contact information such as address, email, and phone number, and other due diligence related information. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.
3. HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
A. Provide Our Services
We use your information to fulfill our contract with you and provide you with our Services, such as:
- Managing your information and accounts;
- Providing access to our Services;
- Answering requests for customer or technical support;
- Communicating with you about your account, activities on our Services, and privacy notice changes;
- Processing applications if you apply for a job we post on our Services; and
- Allowing you to register for events.
B. Administrative Purposes
We use your information for various administrative purposes, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services;
- Short-term, transient use, such as contextual customization of ads;
- Improving, upgrading or enhancing our Services;
- Developing new products and Services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities, including requests to exercise your rights under this Notice;
- Debugging to identify and repair errors with our Services;
- Auditing relating to interactions, transactions and other compliance activities;
- Enforcing our agreements and policies; and
- Complying with our legal obligations.
C. Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.
D. Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.
- Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent. For the sake of clarity, we may need your explicit consent to process your sensitive personal information (e.g., health information, government issued identification, genetic information) for the purpose of providing Services and/or other purposes stated in this Privacy Notice, as well as to transfer your personal information abroad.
- De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, [de-identified location information,] information about the device from which you access our Services, or other analyses we create.
- Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend neighbor, or co-worker).
4. HOW WE DISCLOSE YOUR INFORMATION
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
- Clinical Research Organizations. If you participate in clinical trials and research, the clinical trial sites may disclose any personal information you provide in conjunction with your participation, to the Clinical Research Organization (“CRO”) we have partnered with, that is responsible for organizing the research or conducting the clinical trial. We endeavor not to collect clinical trial participant personal information directly, and other than pharmacovigilance data, all information we receive from the clinical trial sites and CROs are required to be de-identified.
- Clinical Trial Sites. If you request to be matched with a clinical trial site through our referral website, we may share your personal information with the clinical trial site closest to you so that the clinical trial site can contact you about participating in the trial.
- Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
- Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
- Affiliates. We may share your personal information with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide. We may also share your personal information (including but not limited to sensitive personal information) within the country or abroad to our affiliates, through an online system, within the framework of the objectives and principles mentioned above and our internal rules, and in accordance with the methods and conditions indicated in the Law.
- APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
5. YOUR PRIVACY CHOICES AND RIGHTS
- Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Notice).
- Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.
- Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
- Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”);
- Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
- Request Deletion of your personal information;
- Request Restriction of or Object to ourprocessing of your personal information including where the processing of your personal information is based on our legitimate interest or for direct marketing purposes] [and request compensation for the damage; and
- Withdraw your Consent to our processing of your personal information. Revoking your consent does not affect the lawfulness of any processing based on your consent before its revocation.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below or as otherwise instructed in the additional privacy notices provided at the time we collected your personal information. We will process such requests in accordance with applicable laws.
6. SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. The files and records containing your personal information will be kept in our offices and/or on our servers or those of our service providers and only those employees that require it for the purposes of their duties will have access to this file. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
In addition, we determine and implement systematic, clearly defined, manageable and sustainable policies and procedures for the security of your sensitive personal information.
7. INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
If we transfer personal information to countries outside the European Economic Area, we will put in place appropriate safeguards to ensure that this transfer complies with the applicable laws and regulations. For more information about these safeguards, please Contact Us as set forth below.
The files containing your information will be on our servers and those of our service providers and will be accessible to persons that require it for the purposes of their duties. Information may be accessible to the courts and the law enforcement and national security authorities of the United States. To obtain more information about Recludix Pharma’s policies and practices with respect to service providers outside Canada, please Contact Us as set forth below.
While transferring your personal information internationally, we will comply with the applicable requirements governing processing of your personal information in a specific location – for example, your country of residence.
Such transfers shall be carried out in accordance with applicable legal provisions and by obtaining your explicit consent in any way.
8. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental California Privacy Notice only applies to our processing of personal information of California residents. Recludix Pharma does not believe it is subject to the California Consumer Privacy Act of 2018 (“CCPA”). That said, Recludix Pharma provides this supplemental notice for purpose of transparency. The CCPA provides California residents with the right to know what categories of personal information Recludix Pharma has collected about them and whether Recludix Pharma disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
|Category of Personal Information Collected by Recludix Pharma||Category of Third Parties Information is Disclosed to for a Business Purpose|
|Identifiers. unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.||• Data analytics providers|
• Service providers
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Limited to employment context: A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history or any other financial information.|| • Service providers|
• Government entities
|Protected classification characteristics under California or federal law Limited to employment context: Age (40 years or older), race, color, ancestry, national origin, citizenship, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).|| • Service providers|
• Government entities
|Internet or other electronic network activity Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.||• Service providers|
|Professional or employment-related information Current or past job history or performance evaluations.||• Service providers|
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.
“Sales” of Personal Information under the CCPA
For purposes of the CCPA, [Company] does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Recludix Pharma’s business and commercial purposes for “selling” personal information can be found in “How We Use Your Information” above. Recludix Pharma does not have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
Accessibility. This Privacy Notice uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this Notice, please do so from your web browser or by saving the page as a PDF.
California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us as described in this Privacy Notice with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.
11. CHILDREN’S INFORMATION
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.
12. OTHER PROVISIONS
Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.
13. CONTACT US
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:
3545 John Hopkins Circuit, Suite 430
San Diego, CA 92121