Effective as of July 1st, 2023
Debiopharm International SA, Debiopharm Research & Manufacturing SA, and Debiopharm Innovation Fund SA, which are all headquartered in Switzerland (collectively, “Debiopharm,” “we,” “us,” or “our”) provide this Privacy Statement because we know that you care about how your information is collected, used, shared and retained. This Privacy Statement applies to information collected when you visit our website at https://www.debiopharm.com (the “Site”), request our publications, or contact us via the Site.
By visiting our Site, you are agreeing to the terms of this Privacy Statement and the accompanying Terms of Use.
What information we collect; the purpose of collection and use
We collect the following categories of information.
1 – Contact Information
We now or in the future may collect contact information on our Site from visitors who wish to obtain general information, scientific publications, subscribe to our email alerts or contact us about compounds offered for license or in relation to other commercial issues. Contact information is provided and collected via browser forms and may include first name, last name, e-mail address, job title, name of the organization, country, state/region and phone numbers (fax, cell and/or landline), and other information necessary for us to properly respond. This contact information is used by our public relations, search & evaluation teams to contact our Site visitors, and to compile and deliver our response. This is a legitimate interest to use this personal data.
2 – Google Analytics
Like most organizations, we rely on automatic data collection technology (Google Analytics 4(GA4)) when you visit our Site. This allows us to optimize your web experience, analyze the use of the site, and identify and fix technical issues. These are legitimate interests. Google Analytics 4 may use tracking technologies, such as but not limited to cookies to collect information on our behalf such as your IP address, location based on the IP address, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Site you visit, number of links you click while on the Site, search terms, and other data. The information obtained will be transferred to and stored by Google on servers in various countries, including the United States. By accessing and using the Site, you consent to the processing of data about you by Google Analytics in the manner and for the purposes set out in this Privacy Statement. For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Site.
3 – Cookies
Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visits to our Site and other sites as described under “Google Analytics 4,” above. If you do not want us, Google Analytics 4 or the Site to place a cookie on your hard drive, you may be able to turn that feature off on your device. Please consult your Internet browser’s documentation for information on how to do this, such as by using your browser in private mode to block cookies. However, if you decide not to accept cookies from our Site, the Site may not function properly or may prevent you from using some features of our website or dedicated pages on social media. For advertising or social media cookies, we require your consent. These cookies can be allowed or denied by clicking on ‘Manage cookies’ in the footer of our website.
4 – Aggregate Data
In an ongoing effort to better understand our users and the Site, we might analyze your information in aggregate form to operate, maintain, manage, and improve the Site. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, licensees and other contractors within and outside the European Economic Area (“EEA”). We may also disclose aggregated user statistics in order to describe the Site to current and prospective licensees and to other third parties for other lawful purposes.
Additional Uses
We also use Contact Information and Site usage information collected pursuant to this Privacy Statement to respond to general inquiries, solicit feedback regarding our Site, provide relevant content on our Site, and to communicate with you via email regarding our current and future Products, when you have given consent for this.
Involvement of third parties on processing personal data
Like many businesses, we hire other companies to perform certain business and research related services. The types of companies that now or in the future may process personal information and their functions are: Contract Research Organizations, direct marketing assistance, distributors/resellers, data storage, hosting services, disaster recovery services, sales support, and translation services. All such third parties function as our Processors, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Statement and implemented by Debiopharm, one of the measurements is the requirement of a Processor Agreement. When processing takes place outside the EEA, Debiopharm will take appropriate measurements to comply with Swiss Federal Act on Data Protection (FADP) and the Regulation (EU) 2016/679 (General Data Protection Regulation). In particular, we transfer personal data only to countries for which the European Commission has established an adequate level of data protection, or use additional safeguards such as Standard Contractual Clauses approved by the European Commission.
Opt-In to Onward Transfers
We will not disclose your personal information to any third party without first obtaining your opt-in consent unless obliged by applicable law. You may, at any time, withdraw your granted consent, you may do so by emailing us at privacy@debiopharm.com, using this form DSRRFORM
In each instance, please allow us a reasonable time to process your response.
Business Transfers
In the event of a merger, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Statement.
Disclosure to Public Authorities
We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
How we protect personal data; your rights regarding your data
Access to personal information
Upon request to privacy@debiopharm.com, we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time. We may require payment of a fee to pay for our expenses in providing you with such information, in exceptional circumstances.
Your rights
You have the right to access, correct, amend or delete your personal information where it is inaccurate or has been processed in violation of this Privacy Statement. You also have the right to request a copy of your personal information in a generally intelligible form, and the right to request restricting the processing of your personal information when the accuracy or lawfulness is contested. Please use this form DSRRform for your inquiry and allow us a reasonable time to respond to your inquiries and requests.
Retention of personal information
We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Statement, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Statement. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.
How we protect your Information
Debiopharm takes very seriously the security and privacy of the personal information that it collects pursuant to this Privacy Statement. Accordingly, we will implement reasonable and appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.
Children
We do not knowingly collect any personal information from children under the age of 16 through the Site. If you are under 16, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Statement by instructing their children never to provide personal information to us without their permission. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us at privacy@debiopharm.com, and we will endeavor to delete that information from our databases. When we have any reason to suppose we collected Children’s information we will take appropriate action to either find consent of the holder of the parental responsibility of the child or delete the information.
Links to External Sites
The Site may contain links to third party websites (“External Sites”). Debiopharm has no control over the privacy practices of these External Sites. As such, we are not responsible for the privacy policies of those External Sites. You should check the applicable third party privacy statement and terms of use when visiting any External Sites, and before providing any personal information to such External Sites.
Important Notice For Residents of the European Economic Area and Switzerland
Debiopharm complies with the Swiss Federal Act on Data Protection (FADP) and the Regulation (EU) 2016/679 (General Data Protection Regulation), regarding the collection, use, and retention of personal information from the European Union member countries as well as Iceland, Liechtenstein, Norway, and Switzerland. We remain liable if our agent processes such personal information in a manner inconsistent with the GDPR, unless we prove that we are not responsible. If there is a conflict between this Privacy Statement and the GDPR and/or FADP, the GDPR and/or FADP shall prevail.
Debiopharm commits to resolve complaints about your privacy and our collection or use of your personal information.
When you are not satisfied with the way Debiopharm handles you personal data you may file a complaint to the appropriate Supervisory Authority.
Changes to this Privacy Statement
This Privacy Statement is effective as of the date stated at the top of this Privacy Statement. We may change this Privacy Statement from time to time, and will post any changes on the Site as soon as they go into effect. By accessing the Site after we make any such changes to this Privacy Statement, you are deemed to have accepted such changes. In case of major changes we will ask you for additional consent. Please refer back to this Privacy Statement on a regular basis.
How to Contact Us
If you have questions about this Privacy Statement, please e-mail us at privacy@debiopharm.com.
Persons enrolled or participating in a clinical trial sponsored by Debiopharm and who are residents of the European Union may contact Vivenics Consultancy B.V., which is the representative of Debiopharm in the European Union for data protection as well as as in the United Kingdom as well as in the United Kingdom in collaboration with their partner AssureMore. Vivenics Consultancy B.V. and AssureMore may be contacted regarding any data protection issues, including to request information on personal data or any rectification of personal data, or to withdraw any consent.
Eureopean union Representative
Vivenics Consultancy B.V.
Wethouder van Eschstraat 46
5342 AT Oss
The Netherlands
email: representative@vivenics.com
United Kingdom Representative
AssureMore
3 Diamond Avenue
Belfast BT10 0HG
Nothern Ireland, United Kingdom
Email: representative@assuremore.com
Debiopharm may be contacted on any data protection issues at: privacy@debiopharm.com