Priovant Therapeutics and its affiliates ("Priovant", "we", "us", or "our") recognize the importance of protecting your privacy. This Privacy Policy ("Policy") explains how Priovant collects, uses and discloses information in connection with your use of the CLARITY Study website ("Website"), including though the contact forms you use to communicate with Priovant and the communication you have with Priovant using specific email addresses available on the Website. This Policy does not apply to our collection, use, or disclosure of data collected through other means, including other websites (including advertising) operated by third parties that may link to or be accessible from or on the Website.
When you use our Website, you consent to our Terms of Use and acknowledge the collection, use, and disclosure of information about you as described in this Policy. Before you use or submit any information through this Website, please carefully review this Privacy Policy and our Terms of Use. IF YOU DO NOT AGREE TO THIS POLICY OR OUR TERMS, PLEASE DO NOT USE THIS WEBSITE. We will continue to evaluate this Policy as we update and expand the Website and our offerings, and we may make changes to this Policy accordingly. Any changes will be posted here and you should check this page periodically for updates. If we make material changes to this Policy, we will provide you with notice as required by law.
Please note, you may also be subject to another privacy policy or other terms and conditions specific to a particular Priovant program or service ("Other Agreement"). Based upon your specific relationship(s) with Priovant, we may collect, use or disclose your information in ways described in more detail in one or more Other Agreements. To the extent the Other Agreement includes additional terms that are not covered by or are inconsistent with this Policy, the terms and conditions of the Other Agreement will supersede this Policy.
We collect and store information about you in multiple ways, including when you provide information directly to us and when we passively collect information from you, such as from your browser or device.
We collect and store all information that you provide to us when using this Website. You might provide information to us in a variety of ways such as (but not limited to) when you email us at an address provided on the Website or when you fill out a form on the Website.
The information you provide may include, but is not limited to: full name, home address, phone number, e-mail address, and your answers to background information questions.
When you visit any page on this Website, we use a program that monitors and evaluates this Website's traffic. It automatically records every visitor's host, domain name, pages visited, length of user session, browser type and/or IP address.
When you visit and interact with this Website, Priovant and third parties with whom Priovant has contracted to provide services to Priovant, may collect information via cookies, pixels, web beacons, or other tracking mechanisms (for example, a catalog of the site pages you visit, or your IP address), described in more detail below.
This information helps us to improve our Website and to deliver a better and more personalized service.
We may also collect data about your use of the Website through the use of Internet server logs, cookies, and/or other tracking technologies. For more information, please see our Cookies Notice.
We may use the Information we collect from and about you for the following purposes:
We may combine information that we collect from you and about you (including automatically collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy.
We may aggregate and/or de-identify information collected through the Website. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and/or others.
Please note that, based upon your specific relationship(s) with Priovant, we may use your information in ways described in more detail in one or more Other Agreements.
We may disclose your information to certain third parties with whom we have a direct or indirect business or contract relationship, under the following circumstances:
To our affiliates:
We may disclose your information to other companies within the Priovant family of companies.
To our partners:
We may disclose your information to our partners, including other companies and academic institutions who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To service providers:
We disclose your information with third parties who perform services on our behalf, including without limitation market research, data storage, data analysis and processing, and legal services. These service providers are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. When you request other services, we will provide your information to third parties with whom we arrange for those services to be provided.
To protect ourselves or others:
We may also disclose information collected on this Website, in accordance with applicable law, to assert or defend our rights and property, to prevent harm to others, to collect a debt, or in response to legal processes such as subpoenas.
To comply with the law:
We may also provide (or reserve the right to provide) information to regulators, law enforcement authorities, courts, and other governmental authorities, consistent with applicable laws.
For organizational transfers:
As we continue to develop our organization, we may acquire, merge or partner with other organizations. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If any of Priovant's assets are sold or transferred to a third party, customer information (such as your email address) would likely be one of the transferred business assets.
Please note that, based upon your specific relationship(s) with Priovant, we may disclose your information in ways described in more detail in one or more Other Agreements.
Transfers of EU, U.K. or AU personal data outside of the EU, U.K. or AU to third countries (such as United State) will only be made in compliance with GDPR, U.K. GDPR or the Australian Privacy Act, respectively.
If the personal data are transferred by Priovant to countries that have not been recognized by the European Commission or by the U.K. secretary of state as providing an adequate level of data protection, we will put in place contractual safeguards to protect the data (e.g., EU Standard Contractual Clauses “SCCs” to the extent it constitutes a valid mechanism of transfer under Chapter V of GDPR or International data transfer agreement (IDTA) and the Addendum to the SCCs in accordance with Article 46 of the U.K. GDPR).
In case of transfers of Australian personal data outside of Australia (“overseas recipient”), Priovant will take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your information.
If you want to have more details about the mechanism supporting data transfers, please contact us. Our contact information is provided in the “Contact Information” section.
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze the information discussed above, and to engage in auditing, research or reporting. The information (including your IP address) collected by various analytics technologies described in the Cookies Notice will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
If you receive email from us, we may use certain analytics tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
We will only retain your information for as long as necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory requirements.
| The reasons we process your personal information | Legal basis | Retention period |
|---|---|---|
| To complete any requests you make, including requests to be evaluated for potential inclusion in a clinical trial | These processing activities constitute our legitimate interest which is ensuring communication with you as you contacted Priovant with a request. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). | We will process your data for the time necessary to meet your request. |
| To provide, improve, and troubleshoot this Website To generate aggregate statistical studies and conduct research related to our products and services and the use of this Website To notify you about updates and/or products and services from Priovant | Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated when we requested the consent or by contacting Priovant’s DPO. | We will process your data until you withdraw your consent/opt-out. |
| To assert or defend our rights and property, to prevent harm to others, to collect a debt, or in response to legal processes such as subpoenas | Processing is based on our legitimate interest to protect our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). | We will process your data for the time necessary to meet our purpose. |
| To comply with the law | Processing is based on our legal obligations. | We will process your data for the time necessary in accordance with the legal obligations |
On our Website, we may link to third party websites, such as resources of interest for autoimmune disease patients. Please note, Priovant does not control the privacy policies or practices of these third-party sites. You should review those policies before providing any information.
This website also contains a link to another website dedicated to recruitment for CLARITY studies. For more information on how your data is processed there, please read this Privacy Notice.
Priovant has established safeguards to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Your personal data are contained behind secured networks and are only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Although our Website currently does not recognize or respond to the various web browser Do Not Track signals, we do offer you choices to manage your preferences as described in the "Your Choices" section, above.
To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org.
We will provide you with the ability to exercise the following rights under the conditions and within the limits set forth in the law:
Please, note that all of these rights are not absolute and will be assessed on a case-by-case basis.
If you want to exercise your rights, please contact us. Our contact information is provided in the “Contact Information” section.
If you are an EEA resident: You have the right to lodge a complaint with the Data Protection Authority in the Member State of the European Union of your habitual residence, place of work or place of the alleged infringement. Please find the contact information of all Authorities on https://edpb.europa.eu/about-edpb/about-edpb/members_en.
If you are a U.K. resident, you can lodge a complaint to the Information Commissioner’s Office (ICO), the supervisory authority of U.K., through https://ico.org.uk/make-a-complaint/.
If you are an Australian resident, you can lodge a complaint to the Office of the Australian Information Commissioner at https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us.
If you have any questions or concerns about this Privacy Policy or our privacy or security practices, or if you wish to exercise your data privacy rights, you may contact us by e-mail at info@priovanttx.com or write to us in care of: Priovant Therapeutics, Inc., 1007 Slater Road, Suite 250, Durham, NC 27703.
Priovant is the data controller of the personal information as defined by the General Data Protection Regulation (EU) 2016/679 (GDPR) and United Kingdom General Data Protection Regulation, as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (U.K. GDPR).
Priovant is also an APP entity under Australia's Privacy Act 1988.
The data protection representative of Priovant in EU is MyData-TRUST France, located at Valpark – rue Louis Duvant, 1 – 59220 Rouvignies, France.
The data protection representative of Priovant in U.K. is MyData-TRUST Ltd located at Belmont Building, Belmont Road, Uxbridge, England, UB8 1HE, United Kingdom.
Priovant has also appointed a Data Protection Officer/Privacy Officer (DPO), who can be contacted at priovant.dpo@mydata-trust.info.
We may change this Policy from time to time. Please refer to this Policy on a regular basis.
