LEADIANT BIOSCIENCES, INC.
PRIVACY POLICY FOR WEBSITES TARGETED TO US AUDIENCES
At Leadiant Biosciences, Inc. (“Leadiant USA”), we recognize the importance of the privacy of personal information of individuals who visit our company and product websites (“you”).
This Privacy Policy (“Policy”) applies to individuals who visit the websites for our US-based entity and US-marketed products. It addresses how we collect and process personal information about you. It is designed to assist you in making informed decisions when interacting with us, including when visiting our website at https://leadiant.com at the United States tab, or websites of our marketed products that are intended for US audiences (collectively referred to as our “Website”).
Please read this Policy in connection with interacting with us, such as before using our Website. By interacting with us, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Policy. If you do not agree to the terms of this Privacy Policy, please do not access our Websites or provide personal information to us.
This Policy will be assessed and updated from time-to-time to reflect new technologies, business practices and our users’ needs. You should consult this Privacy Policy when you interact with our Company, such as by visiting our Website, to stay current on our Policy, including any updates.
1. Scope of this Privacy Policy
We use the term “personal information” in this Privacy Policy to refer to information that identifies, relates to, describes, or is reasonably capable of being associated, directly or indirectly, with a particular individual person or can be used in context to contact, locate or identify an individual.
This Policy does not apply to:
Anonymized information. Information that has been modified in a substantial way so that it no longer can reasonably be used to identify or be linked to an individual.
Business to business context. Except where legally protected under applicable privacy laws, information about the employees or representatives of healthcare providers, research institutions, pharmacies, and other professional associations, business partners.
Collection by third party websites. Our Websites may contain links to websites that are not operated or controlled by Leadiant USA. The information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of such other websites to understand their information practices.
2. What Personal Information Do We Collect?
We may collect and process the following personal information about you including but not limited to:
- General information – In routine communications and interactions, we collect basic information about you, including your name, postal and/or email address, phone number, date of birth, and other information such as your communications preferences or queries you make to Leadiant USA;
- Professional and business information – We collect your job title and business information and, depending on your interactions with us, may also collect educational information, professional qualifications, work experience, professional networks, programs and activities in which you participated; and
- Digital information – Your use of the Website and other electronic communications with us will generate information, including IP address or mobile device identifier, your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other data transmitted via cookies.
- Patient, family, and caregiver information – In the course of working with healthcare professionals, patient communities, families, and caregivers we may obtain health-related and other personal information about patients who use or are interested in learning about our products and research trials. We may also obtain personal information about patients’ family members and caregivers. Patients and their families may voluntarily provide us with information about their experiences in using our therapies and living with their illness.
Cookies and Their Use
Cookies are small text files created when you visit a website. You can use the settings or tools offered on your browser to refuse or deny cookies, or to delete cookies that have already been stored. (See “Blocking Cookies” below.) They are stored on the user’s computer or mobile device and are sent back to the website or to another website that recognizes the cookie and uses the information to develop a record of the user’s online activity. We may deliver cookies (and similar internet technologies) for our own use as explained below.
In addition, we may include third party links on our Website, such as links to patient organization websites and social media platforms, and those third parties may set a cookie on your device when you activate their link. For example, we may include links to websites of various patient organizations that may be of interest to our visitors. Those services and websites may use their own cookies to collect information on user behavior, demographics, or for personalized advertising. We do not have control over the cookies set by other websites and services, even if you access them from our Website.
Cookies may be used for website functioning purposes and to provide access to secure areas of the Website. We do not use these cookies to track your internet browsing activity beyond our Website. This category of cookies cannot be disabled.
We use analytics programs to gather aggregate data about how visitors use our site, to identify new and repeat visitors, to understand how visitors navigate through our site and which resources are of interest to our visitors. This helps us understand our web page traffic and improve our website. We only use this information for analysis purposes. We do not use this information to attempt to identify you personally, to target personalized advertising to you, or to contact you directly.
Blocking Cookies
Although your browser may be set up to allow the creation of cookies, you can specify that you be prompted before a site puts a cookie on your hard disk, so that you can decide whether to allow or disallow the cookie. Alternatively, you can set your computer not to accept any cookies.
If you wish to restrict or block the cookies on our site, or indeed any other website, you can do this through your browser or mobile device settings.
Please be aware that restricting cookies may impact or reduce the functionality of some websites.
3. How We Obtain Your Personal Information
Leadiant USA may collect information that you submit directly. We also collect digital information from your computer or any other devices you use when you visit our Website (e.g. Internet Protocol (IP), domain name, Internet Service Provider (ISP), information about date and time of your request and other information provided by tracking technologies.) Please also see the section entitled “Cookies and Their Use”.
4. How We Use Your Personal Information
We may use your personal information in a number of ways and the below are some examples.
- Managing our business and providing you goods and services — to administer our business, including to carry out our obligations arising from any agreements entered into between you and us.
- Managing our relationships/communications with individuals — for example, responding to questions and comments or inquiries about applications, trials or services, inviting individuals to Leadiant USA events, identifying future service needs, and enhancing our understanding of how patients use our products and services.
- Sharing patient experiences — patients and their families may voluntarily provide information about their experiences with our therapies that we may make available to others on our Website and other ways who share similar concerns and also help us to better understand the needs of patients and caregivers.
- For collaboration and research purposes — for example to enable Leadiant USA to make more informed and objective decisions when identifying or engaging with healthcare professionals and key opinion leaders and managing the collaboration relationship with healthcare professionals.
- Recruitment — processing professional information to assess the individual suitability for job openings at Leadiant USA.
- Market Research — processing information about individuals for lawful market research purposes. We collect information through surveys and interviews with patients and healthcare professionals to help us improve our products and services.
- To ensure our Website functions — to ensure that content from our Website is presented in the most effective manner for you and for your device.
- Legal or regulatory matters — to comply with our legal or regulatory requirements (reporting for risk management and drug safety obligations, product quality complaints or to fulfill transparency requirements with respect to transfers of value to you by us).
- Protection — to protect individuals (such as our employees, contractors, patients); to protect our information and other assets; to prevent crime (such as fraud, financial crime and theft of intellectual and industry property); and to ensure the integrity of manufacturing and other operations).
- Reorganizing or making changes to our business — Reorganizing or making changes to our business—In the event that we are (i) subject to negotiations for the sale of our business or part thereof to a third party, (ii) are sold to a third party or (iii) undergo a re-organization, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process or for the purpose of analyzing any proposed sale or re-organization. In addition, we may transfer your information to a third party, such as a re-organized entity or third party purchaser, or an acquirer or licensee of an existing marketed product or investigational unapproved compound or asset, to be used for the same purposes as set forth in this Privacy Policy.
- Further processing — for archiving, marketing, scientific and statistical research purposes; to evaluate and improve our products and services.
- Any other purpose — that is relevant to the legitimate and lawful operations and development of our business.
5. To Whom We Disclose Your Personal Information
Leadiant USA discloses personal information to third party recipients where this is permitted to pursue our legitimate business aims and as required or permitted by applicable law. We may disclose personal information to any member of the Leadiant group of companies, which include our international affiliates.
In order to conduct our business, we may also disclose information to third parties such as public/regulatory authorities/governmental bodies (government, including social and benefits departments), third parties that provide services to Leadiant USA (such as but not limited to service providers, conducting audits, providing IT services, assisting in or managing our clinical trials and studies), business partners and collaborators (such as external scientists), third parties who may conduct reviews and assist Leadiant USA with health care compliance activities, or if we are under a duty to disclose or share individuals’ information to comply with any legal or regulatory obligation or request. We may also disclose information to enforce any agreements we have with individuals; or to protect the rights, property or safety of employees, patients or others (e.g. visitors to Leadiant USA premises).
6. Where We Process Your Personal Information
Leadiant USA is located in the United States of America. Personal information about you may be accessed by entities such as companies affiliated with Leadiant USA that are located outside the United States. Your information may also be accessed by staff or suppliers in, transferred to and stored at, a location outside the United States.
7. Third Party Links on our Website
Our Website contains links to the websites of our international affiliated companies and to other third party websites which may have their own privacy policies and terms of use. Leadiant USA has no control over such third-party websites or their content, and this Privacy Policy does not apply to such websites. We do not accept responsibility or liability for the policies or processing of your personal information by websites linked to or from our Website as we do not control the privacy practices of these third parties and we strongly recommend you review the privacy settings they have set up directly with them by visiting their respective privacy related websites and policies.
8. How We Secure and How Long We Retain Your Personal Information
The personal information you provide to us is covered by our security policies and standards that are designed to keep your personal information protected from unauthorized access, disclosure, alteration, and destruction. Such measures may include, but are not limited to: firewalls, access controls, encryption of information while it is in storage, separation of duties, and similar security protocols.
The confidentiality of Personal Information transmitted over the Internet cannot be guaranteed. Leadiant USA urges you to exercise increased caution when transmitting personal information over the Internet, as we cannot absolutely guarantee that unauthorized third parties will not gain access to your Personal Information.
We will retain your personal information for as long as it is needed for the purpose(s) for which your information was collected and any other permitted purpose. Information also may be retained as long as applicable laws or regulations require, or allow.
9. International Users
Please note that our Websites are directed towards users who reside in the United States. If you reside or are located in a different country, the data protection laws of that country may differ from the laws of the United States in the ways your personal information is protected. We want you to understand that when you provide your personal information to us, or we obtain it through your use of our Websites or other means, your information will be transferred to the United States and processed in accordance with the laws of the United States and the guidelines of this Privacy Policy.
10. For Residents of the State of California
This section addresses the California Consumer Privacy Act (CCPA), which provides additional rights and protections related to personal information of qualified California residents. This section does not apply to Leadiant USA personnel or to California residents whose information we obtain in business-to-business interactions.
Under the CCPA, Leadiant USA is required to describe what information it has collected and how it has disclosed personal information to third parties for business or commercial purposes over the past twelve (12) months. The personal information we collect about consumers and the business or commercial purposes for which it will be used are described in the following sections of our Policy:
- What Personal Information Do We Collect?
- How We Use Cookies
- How We Obtain Your Personal Information
- How We Use Your Personal Information
- Why and with Whom We Share Your Personal Information
This Privacy Notice is updated annually and was last updated on June 23, 2020. It applies to our current practices. It also applies to our practices over the twelve (12) months preceding that last update (except as this Privacy Notice may otherwise specify).
Additional information to comply with CCPA-required disclosures include the following:
A) “Do Not Sell My Data” The CCPA requires companies to provide California residents a “Do Not Sell My Data” opt-out option, as well as an opt-in option for minors under 16 years of age. Leadiant USA does not and will not sell the personal information we collect and therefore we do not include these options on our website.
B) “Request to Know & Request to Delete” If you are a California resident covered by the CCPA, you are permitted to (1) request that Leadiant USA disclose to you your personal information that we collect, use, sell or disclose, and to (2) request that we delete your personal information. You may also ask us to provide your personal information in portable format. You also have the option to designate an authorized agent to make a request on your behalf or there may be authority to act on another’s behalf by operation of law (e.g. lawful guardian in case of a minor or power or attorney).
You may submit a request to Leadiant by completing the CCPA Request Form. The CCPA Request Form may be obtained at https://leadiant.com or by sending us a request for that Form by email, at Compliance.Mailbox@Leadiant.com. Once completed, it can be submitted in one of the following ways: (1) at https://leadiant.com or (2) email, at Compliance.Mailbox@Leadiant.com. You may also choose to mail the completed form to us at Leadiant Biosciences, Inc., 530 Gaither Rd., Suite 300, Rockville, MD 20850, Attn: Data Privacy Officer. Alternatively, you may contact us at (800) 447-0169, Ext 3, and we will mail you a copy of the relevant request form.
After you submit the completed CCPA Request Form, we will acknowledge receipt of your request within ten (10) business days and seek certain information from you to verify your identity (and also your authority to make the request on another’s behalf, if applicable), including information that will enable us to confirm that you are a California resident.
If verification has been successful, we will then respond within legally mandated timeframes. Our response may be to provide the information requested, or to make the requested deletion. In some instances, our response may advise that a legal exemption applies and we are not able to comply with the request (such as for a request to delete).
You have a right not to receive discriminatory treatment by Leadiant for the exercise of the privacy rights conferred by the CCPA. We will not discriminate against a California consumer for exercising any of the rights described in this section. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you have any concerns or would like more information regarding these rights, please contact the Data Privacy Officer by email at Compliance.Mailbox@Leadiant.com or call (800) 447 0169, Ext 3.
11. Personal Information of Minors
We do not knowingly obtain personal information from children under 16 years of age without the consent of their parent or guardian. If we learn that personal information from users less than 16 years of age has been collected without the consent of their parent or guardian, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 16, please contact us as explained below under “Contact Information.”
12. Our Changes to this Policy
Leadiant USA reserves the right to amend this Policy from time to time, such as to reflect technological advancements, legal and regulatory changes, and our business practices, subject to applicable laws. If Leadiant USA changes its privacy practices, an updated version of this Privacy Policy will be posted on our Website and all changes to this Policy shall become fully effective immediately, unless otherwise noted. We therefore encourage you to view any amendments when you visit our Website from time to time to stay informed of how we are using your personal information.
13. Contact Information
If you have any questions in relation to this Privacy Policy, or you want to obtain more information about Leadiant USA privacy practices, please contact us by email at Compliance.Mailbox@Leadiant.com or call (800) 447 0169, Ext 3.
