Privacy Policy

BIOSCIGEN (also referred to as “Company,” “we” or “our”) respects the relationships we have with our customers and respects the privacy of all individuals whose Personal Information may be processed by BIOSCIGEN in the performance of our services and our business operations. This Privacy Policy (“Policy”) explains how BIOSCIGEN collects, holds, uses, and discloses Personal Information, including Personal Information of our personnel, consumers, healthcare professionals, patients, medical research subjects, clinical investigators, customers, suppliers, vendors, business partners and investors. BIOSCIGEN intends that this corporate privacy policy and our implementing standard practices and procedures will support timely compliance with all international privacy laws and regulations around the world.

SCOPE: This Policy applies to all Personal Information of Individuals, either in electronic or paper format, received by BIOSCIGEN, including Personal Information of Company Personnel, job applicants, consumers, healthcare professionals, patients, medical research subjects, clinical investigators, customers, suppliers, vendors, business contacts and partners, government officials and investors. BIOSCIGEN endeavors to collect, use and disclose Personal Information in a manner consistent with the laws of countries in which it does business, and has a tradition of upholding the highest ethical standards in its business practices.

DEFINITIONS: For purposes of this Policy, the following definitions shall apply:

“Agent” means any third party that uses Personal Information provided to it by BIOSCIGEN to perform tasks on behalf of and/or under the instructions of BIOSCIGEN or to which BIOSCIGEN discloses Personal Information for use on its behalf.
“European Economic Area” (EEA) means for the purposes of this Policy the following thirty countries: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Italy, Ireland, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden (i.e. countries within the European Union) and Iceland, Liechtenstein, and Norway.
“Individual” means any natural person.
“Personal Information” means any information or set of information about an identified or identifiable individual, including, but not limited to: (a) first name or initial and last name; (b) home or other physical address; (c) telephone number; (d) email address or online identifier associated with the individual; (e) Tax Identification number or other similar identifier; (f) employment or financial information; or (g) any other information relating to an individual that is combined with any of the above. The term “Personal Information” does not include non-identified information or information that is reported in total (provided that such aggregated information is not identifiable to a natural person).
“Company Personnel” includes, but is not limited to, any employee (permanent or temporary), director, officer, contractor, worker, temporary worker, job applicant, retiree of BIOSCIGEN and all their respective dependents.
“BIOSCIGEN” means any entity that directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with BIOSCIGEN Limited. For purposes of this definition, “control” means the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of such entity, whether through the ownership of voting securities, by contract or otherwise.

“Sensitive Personal Information” means Personal Information that reveals or is processed to uniquely identify a person:

All government-issued identification numbers (including Social Security numbers, Canadian Social Insurance numbers, driver’s license numbers, and passport numbers);
All financial account numbers (bank account numbers, credit card numbers, and other information if that information would permit access to a financial account);
Reports of individual background checks;
Data elements revealing race, ethnicity, national origin, political opinion, religious or philosophical beliefs, trade union membership, citizenship or citizenship status, any information that concerns sex life or sexual orientation, or information relating to the commission of a criminal offense;
Precise geolocation data related to workplace locations of healthcare professionals;
Personal Information about individuals under the age of thirteen (13); or
Any other category of information that is regulated as sensitive data or sensitive personal information under applicable data protection laws.

BIOSCIGEN will also treat as Sensitive Personal Information any information received from an employee or third party where that employee or third party treats and/or has identified the information as sensitive. Capitalized terms not defined above have the definitions set forth in the respective paragraphs of this Policy.

NOTICE OF DATA COLLECTION AND USE

Where BIOSCIGEN collects Personal Information directly from Individuals, it will explain the purposes for which it collects and uses Personal Information about the Individuals, the types of third parties to which BIOSCIGEN discloses that information, and the choices and means, if any, BIOSCIGEN offers Individuals for limiting the use and disclosure of Personal Information about them. Notice will be provided in clear and conspicuous language. This explanation will be provided as soon as practicable and, in any event, before BIOSCIGEN discloses the Personal Information or uses such information for a purpose materially different than that for which it was originally collected or processed.

BIOSCIGEN also will provide any additional information required by law for a specific context, product, or service. In general, with exceptions and other lawful bases that may be relevant for any specific product or service notice, BIOSCIGEN processes personal data for its legitimate interests consistent with applicable law. Where an BIOSCIGEN entity receives Personal Information from another BIOSCIGEN entity or other entities, including when acting as a contract research organization (CRO) processing Personal Information under the direction of a customer, it will use such information in accordance with the notices provided by such entities and the choices made by the Individuals to whom such Personal Information relates.

In circumstances in which BIOSCIGEN obtains personal data as a service provider for its clients or affiliates, BIOSCIGEN’s clients or affiliates are responsible for providing appropriate notice to the Individuals and, when applicable, obtaining any requisite consent (unless this function has been delegated to BIOSCIGEN).

BIOSCIGEN may collect various categories of Personal Information (as elaborated on below) for the following purposes:

Research Studies-Related Information. For Individuals participating in research studies being managed by BIOSCIGEN as a CRO or in other situations where BIOSCIGEN is participating in research studies, including patients, their spouses/partners, caregivers, and relatives, clinical investigators or other study personnel, and other consultants, contractors, managers, and agents (who are natural persons) of the study sponsor and its corporate affiliates, business partners and third-party service providers, Personal Information may be used in order to carry out the applicable studies and other study-related services and/or pharmacovigilance. This may include the transfer of such Personal Information to the applicable study sponsor, its corporate affiliates, business partners and third-party service providers performing services related to the study (e.g., study data management, clinical research monitoring services, safety monitoring, etc.).
Human Resources-Related Information. For Individuals who are Company Personnel, we will process Personal Information to carry out and support our human resources functions and activities, including, but not limited to, (i) evaluation of qualifications for an employment position; (ii) provision of employment benefits; (iii) administration and management of employees, compensation, stock options, grants and purchase plans, bonuses, retirement, training, and career planning; (iv) utilizing employee skills and ongoing employee resource allocation; (v) communicating with employees or their emergency contacts; (vi) administration of the company’s business, including budgeting, manpower planning, and organizational design; (vii) authentication of the individual’s identity when gaining access to computer system applications; (viii) Personal Information data changes; (ix) employment status changes; (x) travel and expense planning and reimbursement; (xi) evaluation of employee performance and time management; and (xii) management of Personnel performance, and implementation, investigation and reporting on compliance and discipline procedures and matters. BIOSCIGEN may provide Personal Information to Agents to support BIOSCIGEN in performance of these human resources-related activities. Further, information concerning how BIOSCIGEN collects, uses, shares, and safeguards the Personal Information of Company Personnel is available to BIOSCIGEN Company Personnel in BIOSCIGEN’s internal privacy policy. In addition, for job applicants, Personal Information will be used for the evaluation of suitability of the applicant for a position. BIOSCIGEN may, under its discretion and with the consent of the candidate where required by law or otherwise obtained, perform such background checks as deemed appropriate to evaluate this suitability.
Business Contacts. For Individuals who are business contacts of BIOSCIGEN, BIOSCIGEN may collect Personal Information concerning contact information for such business contacts. This information may be used for purposes consistent with the provision of information by these contacts, which may include marketing activities focused on sales of new products and services, requests to participate in market research that enhances BIOSCIGEN’s product offerings and other business activities.
Health Care Professionals. BIOSCIGEN collects information about health care professionals directly from the health care professionals, from public sources and from business partners. We use this information in connection with various health care activities, including clinical trials, real world studies of patient treatment, health care outcomes analysis, market research activities, and other situations where primary intelligence from health care professionals is applicable.
Customers and Program Participant Information. For Individuals sharing Personal Information with BIOSCIGEN in order to inquire about or otherwise make use of our services or purchase, receive or seek information, including about any health care products and services, opportunities to participate in clinical research, health care education and patient support programs which may be available through BIOSCIGEN, we will use such Personal Information in order to provide the requested information, products, and/or services. Such uses may include, but are not limited to, processing requested transactions, improving the quality of our services, sending communications about the products and services available through BIOSCIGEN, and enabling our business partners and Agents to perform certain activities on our behalf.
Data Analytics Functions. In certain situations, BIOSCIGEN obtains and processes information about Individuals for various data analytics purposes. In most situations, this data has been anonymized or de-identified and is no longer Personal Information when it is obtained by BIOSCIGEN or whenever transferred. In some situations, BIOSCIGEN receives Personal Information from a customer or other data supplier for the purpose of such anonymization or de-identification. In other situations, the data that is obtained and processed by BIOSCIGEN is pseudonymous. This pseudonymous information may be used for research purposes, primarily in connection with academic partners and with academia, and may be transferred by BIOSCIGEN to the United States as part of these research-related activities. For all these situations, BIOSCIGEN’s activities are consistent with the notice and choice provided by these customers or data suppliers to Individuals, and BIOSCIGEN’s use of this information is consistent with BIOSCIGEN’s obligation to provide services to these entities. In those situations, and where such information is transferred to the United States, BIOSCIGEN uses such information only in manners consistent with appropriate data transfer mechanisms and the way this data was obtained.
Our commercial purposes. We may choose to rent, release, disclose, disseminate, make available, or sell your Personal Information or Sensitive Personal Information to our business partners in return for monetary or other valuable consideration. We may use your Personal Information for purposes of targeted advertising. Additionally, your use of our website and online services may allow third parties to collect your Personal Information or Sensitive Personal Information over time and across different Internet websites. We do not use your Personal Information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects.

Please note that in certain instances, we implement additional protections (such as by obtaining consumer consent in relation to the use cases described above) to ensure that our data processing activities are following applicable law.

BIOSCIGEN may also use the Personal Information collected above to comply with our legal and regulatory obligations, policies, and procedures, and for internal administrative purposes. We may also collect, use, and disclose Personal Information that we collect online for any purpose outlined in our Online Privacy Policy.

OTHER DISCLOSURES OF PERSONAL INFORMATION

In some cases, BIOSCIGEN may disclose Personal Information (i) if required to do so by law, court order or legal process, (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, (iii) under the discovery process in litigation, (iv) to enforce BIOSCIGEN policies or contracts, (v) to collect amounts owed to BIOSCIGEN, (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity, or (vii) in the good faith belief that disclosure is otherwise necessary or advisable. BIOSCIGEN also may transfer Personal Information when a material event concerning its business operation(s), assets, or shares, such as purchase, disposal, merger, joint venture, or acquisition, is proposed or occurs. In such an event, BIOSCIGEN will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Policy. BIOSCIGEN will provide Individuals with reasonable mechanisms to exercise their choices to the extent required by applicable law.

ACCOUNTABILITY FOR ONWARD TRANSFER

In the performance of our services and business operations, Personal Information we collect or receive may be stored or transferred internationally throughout our worldwide organization and to our service providers or agents, including for hosting our databases or provision of data processing services, in accordance with applicable data privacy laws. Transfers to third parties are covered by the provisions in this Policy regarding notice and choice.

BIOSCIGEN may also share an Individual’s Personal Information with Agents, including affiliates, in connection with services or business purposes that these individuals or entities perform for, or with, BIOSCIGEN. BIOSCIGEN may, for example, provide an Individual’s Personal Information to Agents for hosting our databases, for data processing services, or to send to that Individual the information that he or she requested.

BIOSCIGEN may transfer Personal Information for specified, limited purposes to an Agent and will endeavor to obtain assurances that such Agent provides at least the same level of privacy protection as is required by appropriate data transfer mechanisms and this Policy and will notify BIOSCIGEN if it makes a determination that it can no longer meet this obligation.

Where BIOSCIGEN knows that any third party to whom it has provided Personal Information is using or disclosing Personal Information in a manner contrary to this Policy, BIOSCIGEN will take reasonable steps to prevent or stop the use or disclosure. With respect to such onward transfers to Agents, and to the extent BIOSCIGEN is responsible for the event, BIOSCIGEN shall remain liable should its Agents process Personal Information in a manner inconsistent with the appropriate data transfer mechanisms and this Policy.

In circumstances in which BIOSCIGEN obtains Personal Information as a service provider for its clients or affiliates, BIOSCIGEN’s clients or affiliates are responsible for protecting individual rights with respect to onward transfers.

SECURITY

BIOSCIGEN will endeavor to take reasonable and appropriate technical, administrative and physical safeguards designed to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Information BIOSCIGEN is processing, and regardless of whether such Personal Information is in electronic or tangible, hard copy form. We have a privacy incident response program designed to promptly respond to and escalate all privacy-related questions, complaints, and concerns, including any potential privacy or security incident.

DATA RETENTION

The information we collect may be archived or stored periodically by us according to backup processes and will only be retained for as long as is required for the purposes for which it was collected, as well as to provide our products and services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

DATA INTEGRITY AND PURPOSE LIMITATION

BIOSCI GEN endeavors to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the Individual. BIOSCIGEN will take reasonable steps designed to ensure that only Personal Information that is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained is used by BIOSCIGEN for as long as BIOSCIGEN retains possession of such information. BIOSCIGEN’s Personnel have a responsibility to assist BIOSCIGEN in maintaining accurate, complete, and current Personal Information. When acting as a CRO or in other situations where BIOSCIGEN acts on behalf of another entity, BIOSCIGEN endeavors only to process Personal Information that is relevant to the services it provides, and only for purposes compatible with those for which the Personal Information was collected; wherever possible, such Personal Information is non-identified. Where BIOSCIGEN processes Personal Information as a CRO or otherwise acts under the direction of its customers, BIOSCIGEN collaborates with such customers so that the customers can provide a way for Individuals to correct or update their Personal Information to the extent required by law.

YOUR PRIVACY CHOICES

Depending on your area, you may also have certain legal rights in relation to the processing of your Personal Information. These rights may include:

The right to access your personal information (including a data portability request);
The right to correct or amend any personal information we have on file about you;
The right to delete your personal information;
The right to limit the use of your “sensitive” personal information;
The right to opt-out of the sale or “sharing” of your personal information;
The right to opt-out of the use of your personal information for targeted advertising purposes;
The right to restrict or object to the processing of your personal information (such as for direct marketing purposes);
The right to restrict the use of your personal information for certain automated decision-making (including profiling); and
The right to revoke your consent (to the extent applicable)

To exercise any of these rights, please fill out this webform or contact us by email at privacyofficer@bioscigen.com with your name, physical address, email address, the email address associated with your interactions with BIOSCIGEN (if different), telephone number, and details about your interactions with BIOSCIGEN (including whether you are a patient or a health care professional). You may also designate an authorized agent to submit a request on your behalf. To designate an agent, please also send us a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. Please note that we will still require you to provide sufficient information to allow us to verify that you are the person about whom we are receiving a request. We will respond to any request you submit in the period required by applicable law and will allow you to appeal any decision we make in response to such request in accordance with applicable law. Appeals may be submitted to privacyofficer@bioscigen.com.

Although BIOSCIGEN makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which BIOSCIGEN is unable to provide access, including, but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If BIOSCIGEN determines that access should be restricted in any instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.

RECOURSE, ENFORCEMENT AND LIABILITY

BIOSCIGEN encourages Individuals covered by this Policy to raise questions about the processing of Personal Information about them by contacting BIOSCIGEN through the contact information provided below. Any Personnel that BIOSCIGEN determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment, where applicable, in accordance with BIOSCIGEN’s disciplinary procedures.

Any questions or concerns regarding the use or disclosure of Personal Information should also be directed to BIOSCIGEN through the contact information given below. BIOSCIGEN will undertake reasonable efforts to investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy.

In circumstances in which BIOSCIGEN obtained or maintains Personal Information as a CRO or other Service Provider, Individuals may submit complaints concerning the processing of their Personal Information to the relevant client, in accordance with the client’s dispute resolution process. BIOSCIGEN will participate in this process at the request of the client or the Individual. BIOSCIGEN will take steps to remedy any issues arising out of any potential failure to comply with this Policy and, where applicable, implement appropriate data transfer mechanisms.

CONTACT INFORMATION: Questions, comments, concerns or complaints regarding this Policy or BIOSCIGEN’s processing of Personal Information should be submitted to the BIOSCIGEN Privacy Officer at privacyofficer@bioscigen.com.

RESERVATION OF RIGHTS: BIOSCIGEN reserves the right to share an Individual’s Personal Information and contracts with Agents as required or authorized by law or regulation or in response to duly authorized information requests of government authorities.

CHANGES TO THE PRIVACY POLICY: This Policy may be reviewed and amended from time to time, without advance notice, to ensure that an appropriate level of protection for Personal Information is maintained. All amendments will be posted on this website. Please check back periodically for updates to this Policy.

BIOSCIGEN PRIVACY POLICY EFFECTIVE DATE: July 31, 2024