Caprion

Accelerating precision medicine™

Privacy policy

Introduction

This website (the "Site") is provided by Caprion Biosciences a leading specialty clinical research organization laboratory. Consulting these pages will help you familiarise yourself with and understand our latest data-protection policies. We encourage visitors to our web-site and users of our services to take active responsibility for the protection of their personal data and their privacy.

When You register and/or submit information through Our website, You will be invited to provide express consent to the use of Your personal information in accordance with this Privacy Policy.

Who We are

CAPRION Biosciences Inc. is a company incorporated according to the laws of the State of Québec in Canada, number 1171946586, whose registered office is at Suite 3900, 201 avenue Président-Kennedy, in Montréal, Québec H2X 3Y7 (“CAPRION Québec”).

CAPRION Québec is also registered as a foreign enterprise in Belgium, company N° 0660.984.526.

CAPRION BIOSCIENCES SA is [a majority (99%) owned subsidiary of CAPRION Québec]. CAPRION BIOSCIENCES SA is a company incorporated according to Belgian law, company N° 0661.567.021, whose registered office is at 8, Rue Adrienne Bolland, Boîte 2, in 6041 Charleroi, Belgium. (“CAPRION Belgium”).

PRIMITY BIO, INC. is a wholly owned subsidiary of CAPRION Québec. PRIMITY BIO, INC. is a company incorporated according to the laws of the State of Delaware, File N° 4713423 whose principal address is at 48383 Fremont Boulevard, Suite 118, in Fremont, California 94538, USA. Its registered agent in the State of Delaware is Incorporating Services, Ltd., 3500 South Dupont Highway, Dover, Kent County, Delaware 19901, USA ("PRIMITY")

In the remainder of this document CAPRION Québec, CAPRION Belgium and PRIMITY are referred to together as "CAPRION". "We" / "Us" / "Our".

Where the context requires, CAPRION Québec, CAPRION Belgium and PRIMITY may also be referred to together below as the “CAPRION Companies”.

  1. Summary

    CAPRION is committed to protecting Your privacy. The general purpose of this Privacy Policy is for Us to tell You about the policies and procedures that We have in place to safeguard Your privacy; to explain how We may use any personal data (the “personal information”) that We collect about You ("You" / "Your"); and to explain Your rights and how you can limit the use of that personal information.

    When You consult Our Site, or sign up to receive one of Our newsletters or other services, We will use Your personal information to provide You with the service You have requested.

    We may process and aggregate information about how You navigate on the Site in order to analyse usage and to better manage the Site.

    If You have consented:

    • CAPRION may use Your information for marketing or promotional purposes;
    • We may share Your information with trusted third parties, or for analytics purposes, so that Your information for may be used for surveys, marketing and for related purposes.

    Some of these organisations may be based in countries outside the European Union. If We transfer Your personal information to such a country We will take steps to ensure Your information is appropriately protected.

    We also reserve the right to transfer your personal information to a third party: (i) if We’re under a duty to comply with a legal obligation; (ii) to protect the rights, property or safety of others; or (iii) to enforce Our Terms of Use. [However, We will also take steps for the purpose of ensuring that Your privacy rights continue to be protected.]

  2. Further Information

    If You would like to learn more about Our data collection policies and practices, please read the following paragraphs of this Privacy Policy:

  3. Personal information

    "Personal information" means any data about You from which You can be identified such as Your name, address, telephone number, email address, curriculum vitae, qualifications and positions held or other personal information which You may disclose to Us via the Site at any time including for recruitment purposes.

  4. When do We collect Your personal information?

    We collect the personal information which You submit to Us when signing up for services provided on the Site. We also collect certain personal information automatically when You enter and use this Site. (Automatic data collection is explained in more detail at paragraph 8 below under the heading IP addresses ‘click-stream’ data and cookies.)

    If You do not agree with this Privacy Policy and in particular with our explanation of How We use Your personal information (paragraph 7), please exit the Site and do not submit any personal information to Us.

  5. Privacy protection for young persons

    This site is aimed at and intended for use by our existing and prospective clients and by other business users. You must be at least 18 years old to register and submit personal information on this site. If You are under 18 years of age You cannot register to use this site and a parent or guardian may not assist you to register nor register in Your name. If We learn that a user is under the age of 18, We will take appropriate steps to remove his or her information from Our database.

  6. Your rights in relation to Your personal information

    You have the right:

    • to access Your personal information and to be informed about its use
    • to correct Your personal information
    • to have Your personal information deleted
    • to restrict the use of Your personal information
    • to object to the use of Your personal information
    • to complain to a supervisory authority
    • to withdraw Your consent to the use of Your personal information
    • to ask for the portability of the personal information You shared with Us

    You have the right to access personal information that We keep about You. Furthermore, You may ask Us to make any necessary changes to ensure it is accurate and up-to-date. You can also request deletion, or a limitation of the treatment, of Your personal information. You also have the right to object to any processing of Your personal information.

  7. How We use Your personal information

    Personal information that We obtain about You will be used in accordance with current data protection legislation and this Privacy Policy. We, or data processors acting on Our behalf, will process your personal information as follows:

    For the legitimate interests of the CAPRION Companies

    • To provide You with information about CAPRION; or
    • To provide You with information on Our Services [including promotions, new business opportunities and information about companies doing business with CAPRION] and to ensure that such information is tailored to Your needs and interests and Your use of our Site; or
    • To send You information about events that may be of interest to You; or
    • To ensure the security of our web site, [mobile applications] [and other technology systems]; or
    • To deal with any enquiries made by You including for the following purposes:

      • To process Your registrations for Events;
      • To send you Caprion’s newsletters;
      • To submit targeted information related to your interests

    We may occasionally use Your email address and, in rare situations, postal address or phone number, to contact You regarding administrative matters or notices and to manage and respond to any queries You make or any correspondence that You send Us.

    • To comply with a legal obligation, including where You exercise Your rights to make requests under data protection law and to comply with lawful requests from government or law enforcement officials.

    Based on your consent, for the following purposes:

    • To send You marketing communications including by e-mail;
    • If for any reason including for recruitment purposes You provide Us with sensitive personal information.

    We may also use aggregated personal information:

    • For market research and statistical analysis; and
    • To analyse the use of Our Services so that We can improve them.

    We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example accounting). We will hold Your personal information on Our systems for as long as is necessary for the relevant activity, or, where applicable, for as long as is set out in any contract that You hold with Us.

  8. More about collection of Your personal information

    IP Addresses ‘Click-stream’ data and cookies

    An IP address is a number which is automatically assigned to Your computer whenever You access the Internet. When You access Our Site, We log Your IP address and can identify the device you are using from it. Click-stream data is information collected by Us when You navigate the Site, for example the specific Web pages You looked at, the order in which You looked at them and the time of Your visit. This data helps Us analyse how visitors arrive at the Site and what content is most popular and We may use it for administration purposes or to analyse aggregate information. We collect this information using cookies. You can read more about how cookies work in Our cookies policy

    .

    Our Site pages may also contain electronic images known as ‘web beacons’ which are used along with cookies to compile aggregated statistics to analyse how Our Site is used. Web beacons may also be used in some of Our emails to let Us know which emails and links have been opened by recipients.

  9. Optional and Future Services

    There are a number of optional services for which You may choose to sign-up. The personal information requested may vary for each service which is offered. This paragraph explains the information We collect for each service, and how We may use it. (This information complements the more general information given in paragraphs 7 and 8 above.)

    Newsletters, emails and alerts

    You may sign-up to receive a newsletter or other alerts either by direct registration or in conjunction with a particular service or membership for which You have registered. When You sign-up, We will ask You what information you would like to receive about CAPRION. If You agree, We may share Your information within the CAPRION companies. You can cancel Your subscription to newsletters and other alerts at any time by writing to Us using the ‘Contact Us’ information in paragraph 14.

    Surveys

    From time-to-time We may ask You to participate in surveys made available on or through the Site. Participation is voluntary but may involve disclosure of certain personal information. Each survey will explain how such personal information will be used and whether it will be aggregated or anonymised to help protect Your privacy.

  10. Disclosure of Your personal information to third parties and overseas transfers of Your personal information

    We may pass Your information to third party electronic service providers working on Our behalf for the purposes of carrying out data processing and providing services to You (for example to send You newsletters to which You have subscribed).

    We will share Your personal information with certain parties, depending upon the purpose for which the information was provided, the consents which You give at the time the information is provided and the context in which the information was provided, as described in the following paragraphs. We require such third parties to only use the information for the purpose for which it was provided.

    We may share Your information within the CAPRION companies who are subject to this privacy policy.

    We may also pass Your personal information to other parties as follows:

    • To regulatory bodies, legal advisers, the police or parties whose request We reasonably consider to be justified in connection with any alleged criminal offence, any suspected breach of the CAPRION Terms of Use or any other abuse of Our services by You.

    Transferring Your information outside of the EU

    Our service providers are located outside the EU, we may collect, transfer or store personal information through servers located in the USA or in another country outside the EU. In any such case we will ensure that Your data is only transferred to a non-EU based service provider who can provide equivalent protection for Your personal information to that which is available in the EU and that Your personal information is processed in accordance with this Privacy Polciy. For example by using contractual clauses approved for the transfer of personal information to third countries. We also ask Your consent for such transfers when You register with Us.

  11. How do We protect Your personal information?

    We use security measures to protect Your personal information from any access by unauthorised persons and against unlawful processing, accident loss, destruction and damage.

    Once We receive your information, We take security measures [in accordance with IT industry standards], including physical, organizational and technical measures, to protect Your personal information. However, it is impossible to fully guarantee the security of personal information transmitted over the internet. Therefore We cannot absolutely guarantee the security of the information that You transmit to Us one hundred percent.

  12. Unsubscribing or amending Your personal information

    You are entitled to obtain details of what personal information CAPRION holds about you free of charge by sending Us a written request.

    If you wish to change Your email address or any of the other information we hold, or if the information is inaccurate, please send a letter:

    Attn: Privacy Compliance Officer
    Caprion Biosciences Inc.
    201 President Kennedy avenue, Suite PK-3900
    Montreal, Quebec, Canada
    H2X 3Y7

    Or, please e-mail: privacy.compliance@caprion.com

    You may also contact Us at any time if You wish to amend or remove information that You have provided to Us via the Site, or wish to withdraw any consent concerning the collection, processing or use of Your personal information. You can do this by writing to Us at one of the addresses given above. (See also paragraph 14, Contact Us, below.)

  13. The Site may contain links to other websites. CAPRION is only responsible for the privacy practices and security of this Site. [Neither] the CAPRION companies [nor any other CAPRION entity] are liable for any privacy policy, security policy or content or of any kind that may be part of a site to which our Site suggests a link.

    We recommend that You check the privacy and security policies of each website that You visit including any visited through a link found on Our Site.

  14. Contact-us

    If You have any comments or questions about this Privacy Policy, Our processing of Your personal information, the practices of this Site, or Your dealings with CAPRION, please send Us a written request. Your request must include Your name, email address and/or postal address. Written requests sent by post must also be signed.

    We may take reasonable steps to verify Your identity before granting access or making corrections or providing for deletion of Your personal information. (Please note that your right of access is not absolute and may be subject to applicable legal restrictions in certain limited cases.)

    Please send a letter:

    Attn: Privacy Compliance Officer
    Caprion Biosciences Inc.
    201 President Kennedy Avenue, Suite PK-3900
    Montreal, Quebec, Canada
    H2X 3Y7

    Or, please e-mail: privacy.compliance@caprion.com

  15. Review of this Privacy Policy

    We keep this Policy and its contents under regular review. It was last updated on the 30 of October 2018. We recommend that You consult these pages from time to time so that You are aware of Our latest policies.