EU and UK Privacy Notice

This Privacy Notice is addressed to European Union (“EU”) and United Kingdom (“UK”) website users, clinical trial participants, and other EU and UK individuals whose personal data we process in the context of our EU or UK operations (each “Data Subject”). This Privacy Notice is meant to help you understand what personal data we collect, why we collect it, and how you can exercise your data protection rights.

You might have been provided with a privacy notice or contract for a specific purpose—for example, in connection with your participation in our clinical trials. If that is the case, the terms of the notice or contract will control your interaction with Transcend, to the extent that such notice or contract conflicts with this privacy notice.

PROCESSING OF YOUR PERSONAL DATA

We collect, use, share, store, or otherwise process your personal data where applicable law permits or requires it, including where the processing is necessary for the performance of a contract with you, where the processing is necessary to comply with a legal obligation that applies to us, for our legitimate interests or the legitimate interests of third parties, to protect your vital interests, or with your consent if applicable law requires consent. We may process your personal data for the following legitimate business purposes that include the following:

Providing the Website and associated functionality.
Providing information to our potential strategic partners, vendors, investors, clinical sites, and investigators to learn more about us.
Facilitating our scientific research, including in connection with recruiting and administering clinical trials.
Communicating with you, including by responding to your inquiries, fulfilling your requests, and promoting our Website, our research, and our treatments.
Communicating with our contractors, service providers, and other third parties we use to support our Website and our organization.
Providing, developing, maintaining, personalizing, protecting, and improving our Website, our operations, our organization, and our potential drug offerings.
Operating, evaluating, debugging, identifying, and repairing errors, effectuating functional enhancements.
Understanding how you and others use our Website, performing analytics, analyzing, and reporting on usage and performance of our Website.
Investigating or preventing unlawful activities, including misuse of our Website.
For legal and safety purposes, such as maintaining the safety, security, and integrity of our Website, our clinical trials, other assets, operations, our research, and our organization and protecting the legal rights, property, safety, and security of us, our users, our site participants our employees, and others. Protecting against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
Enforcing our policies, terms of use, contracts, or other legal rights.
Evaluating or participating in an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.
Creating aggregate or de-identified data.
Complying with law and legal obligations.

Please refer to the individual data privacy notices which we provide in the context of our business communication with you, for further details about the corresponding processing of your personal data in this context. Examples of this may include an informed consent form.

CATEGORIES, TYPE OF PERSONAL DATA COLLECTED

Information that you choose to provide.

You may choose to provide personal data, such as the following:

Personal data you provide to us when you fill out and submit our “PI/Site Interest Form,” including the principal investigator name, site contact name, email address, telephone number, location, therapeutic area/specialty, patient treatment experience, areas of research interest, clinical trial participation history, the principal investigator’s CV, and any additional personal data you choose to provide.
Any personal data you provide in a submission through our “Contact Us” form or other contact methods.
Personal data associated with your participation in clinical trials, including medical information.
Any other personal data you provide.

Information that we collect automatically.

We may also collect certain other information automatically when you visit our Website, such as the
following:

Browser and Device Information: When you visit our Website, we will collect certain information that is automatically collected by most websites, such as information about your device and your browser. For example, we may receive device identifiers such as your IP address and MAC address, operating system type and version, and Internet browser type and version.
Search Engine and Other Referrals: When a third party refers you to our Website, such as through your clicking on a link to our page from a Google search, we may receive some information about your device and your interaction with the referring site or content.
Information Stored in Cookies, Pixels Web Beacons, and Other Similar Technologies: We and other third parties with whom we work may also use available web-based technologies to collect information about your use of our Website, such as cookies or web beacons. A
“cookie” is a unique numeric code that is transferred to your device to track your interests and preferences and to recognize you as a return visitor. A “web beacon” is a transparent graphic image placed on a website, email, or advertisement that enables the monitoring of things such as user activity and site traffic. We use these and other similar technologies to collect information such as browser type, transactions and interactions, time spent on the online services, pages visited, referring URL, and other traffic and usage data. We may use this information to determine what features interest our users, revise our site features or operations, and as further described below. We and other parties that provide these technologies may also use these technologies to collect information about your online
activities over time and across third-party websites or other online services. For more information, see the “Your Choices” section below.
Information Collected in Connection with Analytics Technology: We may use various technologies to learn more about how visitors use our Website, such as Google Analytics. Google Analytics uses cookies to help us analyze how visitors use our Website. The
information generated by the cookies about your use of our Website includes your IP address. If you so choose, you may be able to opt out by turning off cookies in the preferences settings in your browser. For more information on Google Analytics, including how Google Analytics collects, uses, and discloses information, refer to the following page: www.google.com/policies/privacy/partners/. We may also use other technologies to monitor your activities on our Website.

SECURING AND PROCESSING YOUR PERSONAL DATA

We take technical and organisational security measures that are designed to protect your personal data.

SHARING OF PERSONAL DATA

We may disclose personal data:

To our current and potential strategic partners, vendors, investors, clinical sites, and investigators.
To regulatory bodies and governmental entities, including law enforcement entities.
To parties and networks that we use to conduct internal analytics.
To our contractors, service providers, and other third parties we use to support our organization, our Website, our research, and our treatments.
To comply with law and legal obligations.
To enforce our policies, terms of use, contracts, or other legal rights.
To investigate or prevent unlawful activities, including misuse of our Website.
To protect against malicious, deceptive, fraudulent, or illegal activity, and participate in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
To operate, evaluate, debug, identify and repair errors, effectuate similar functional enhancements, and improvements, including to our Website.
To protect the legal rights, property, safety, and security of our organization, our users, our employees, and others.
To an actual or potential investor, buyer, successor, or other person or organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of, or investment in, some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.
To such other parties as you may authorize or that we otherwise disclose.
For any additional purposes described in the Processing of Your Personal Data section above.

INTERNATIONAL DATA TRANSFERS

We may at times transfer your personal data to other countries, whose data protection and privacy laws may not be equivalent to, or as protective as, those that exist in your country of residence. Transfers will be done in compliance with the international data transfer restrictions that apply under data protection laws, including, where appropriate, through the use of standard contractual clauses for international transfers.

HOW LONG DO WE KEEP YOUR PERSONAL DATA

Personal data will be kept for so long as it is reasonably necessary to fulfil purposes for which it was collected. As an exception, we may be required to retain your personal data for longer periods as required or permitted by law, or as necessary to protect our rights and interests. In such a case, you will be informed of the intended retention period in the applicable document, such as a privacy notice or an informed consent form.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

You have a number of rights related to the personal data that we Process about you (this will depend on the jurisdiction where you reside and the legal basis that we use). Most often, exercising your right is free of charge. We may also have to clarify your request and explain if we can comply with it or if this is restricted in your situation. Below we have listed individual rights that may apply depending on your jurisdiction.

You may have the right to:

Receive a copy of the personal data we hold about you – Right of Access
Correct the personal data we hold about you – Right to Rectification
Ask us to delete your personal data or restrict how it is used in certain circumstances- Right to Erasure
Request that we cease processing your personal data in certain conditions – Right to Restrict Processing
You have the right to object to our processing in certain circumstances – Right to Object
Information related to Automated decision making or profiling – We do not use automated decision-making or profiling.
Lodge a complaint to your designated Supervisory Authority- Right to lodge a complaint
In some instances, we may ask for your consent to collect and use your personal data. Should you choose to provide your consent, you may later withdraw your consent by contacting us. If you have consented to a particular purpose for our use of your personal data, then we may rely on your consent until you withdraw it. Please note that the withdrawal of consent will not affect processing that has already occurred – Right to withdraw consent

EXERCISING YOUR RIGHTS, MAKING AN ENQUIRY OR COMPLAINT

If you took part in a clinical trial as a study subject, you should ideally contact the institute where your trial took place (as we will not be able to identify you from the study data). Contact details will have been given on your Informed Consent Form or Patient Information Sheet. You may also contact us directly using the details below.

Email: privacy@transcendtherapeutics.com

Data Protection Officer: dpo@transcendtherapeutics.com