A. Information you provide to us
We and our affiliates and companies and individuals that provide services to us and on our behalf (“Service Providers”) collect and store information that you choose to provide when you use the Sites, including but not limited to when you register to access the Sites, sign up to receive emails or other communications, apply for a job, report a safety-related event related to one of our products (e.g., an adverse event, use during pregnancy or lactation, suspected interaction with other products, treatment errors such as overdose, usage outside the conditions in the label), or otherwise contact us with a question, comment, or request. This can include, but is not limited to: (a) your name, contact information, sex, and other registration information; (b) health information; (c) information you provide when submitting an employment application form; (d) health, biometric/genetic information related to identifiable or non-identifiable individuals, and only where necessary and strictly permitted under applicable law; and (e) information you provide us when you contact us. If you report an adverse event or reaction involving one of our products, we may ask you for additional information, for example, to help us meet our reporting obligations under applicable law.
Please note that while you are logged in to an Ichnos Site, your actions in that browsing session may be associated with your information. We may combine the Personal Information you share with us through a Site with other information you have shared with us, both online and offline. We may also combine this Personal Information with records provided by third parties. We use this consolidated information to help us better design Ichnos products, to communicate information to you, to enhance our marketing and research activities, and to facilitate other business functions. However, Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
If you are a medical professional and are using the Sites for reasons other than reporting a product experience, you should make sure that you do not disclose identifiable information about your patients where not authorized by law.
B. Information automatically collected from you
We and our Service Providers automatically collect and store certain technical information with the goal of improving the content and services offered on our Sites during each user visit, but do not use this information to personally identify you. This technical information includes: (i) the domain and host from which you access the Internet; (ii) the internet address of an Ichnos Site from which you linked directly to the Ichnos Site, if applicable; (iii) the date and time you arrived at our Site and how long you spent on the Site and which pages you visited; (iv) your Internet Protocol (IP) address; and (v) your computer’s operating system and browser software. We and our Service Providers may collect this information using “cookies,” which are small text files that the Sites save on your computer using your web browser and access when you return, web beacons, tracking pixels, or other technologies. For more information about technical tracking technology used on our Sites, please see the section on Cookies.
C. Information from outside sources
In certain instances, we collect information about you from other public or third-party sources, such as (i) information about healthcare professionals in order to verify their licensure status, professional information and identity; (ii) healthcare professionals or other third parties who may provide patient information to Ichnos where necessary under applicable drug safety and risk management laws.
Personal Information may be shared within Ichnos affiliates.
In addition to the above, where Ichnos processes special categories of data about individuals in specified jurisdictions (including European Economic Area) – for example, information about individuals’ health, genetic, religious, ethnicity, religion, trade union membership, genetic and biometric data, sexual orientation or sex life) – it shall only do so in accordance with the obligations of the law.
Ichnos relies on conditions including, but not limited to:
We use the information we collect for a number of purposes permitted by applicable law, including, but not limited to:
We will not sell or otherwise disclose any Personal Information or any other information associated with those data elements we collect about or from you through the Sites to any third parties without your consent, except as follows:
We may use or share aggregated data (information about our base of users in general, from which all Personal Information has been removed) for any purpose.
Information collected through the Sites will be processed in and subject to the laws of the United States, which may not provide the same level protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside of the United States to our affiliates, business partners, and Service Providers located in other countries. By using the Sites, you consent to such transfer to, and processing in, the United States and these other countries.
For residents of European Economic Area (“EEA”) – whenever we transfer your information outside of the EEA or Switzerland, we will take necessary steps to ensure that adequate safeguards are put in place to protect your information. Such safeguards include the use of European Commission approved standard contractual clauses.
Ichnos Sites may make social media sites, forums, and message boards available to its users. Please remember that any information that is disclosed in these areas becomes public information. You should exercise caution when deciding to disclose your personal information and you should not disclose the personal information of anyone other than yourself. Ichnos cannot ensure or warrant the security of any information provided by you in such forums, and you do so at your own risk.
The Sites may use social media plugins (e.g., the Facebook “Like” button, LinkedIn “Share” or “Follow”) to enable you to easily share information with others. When you visit our Sites, the operator of the social plugin may be able to place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our site. If you are logged into the associated social media website (e.g., Facebook or LinkedIn) while browsing on our Sites, the social plugin allows that social media website to receive information that you have visited our Sites. The social plugin may also allow the social media website to share information about your activities on our Site with other users of their social media website. For more information about the information shared via a particular social media plugin, you should refer to that social media site’s privacy statement.
Depending on their purpose, some cookies will only operate for the length of a single browsing session, while others have a longer life span to ensure that they fulfill their longer-term purposes. Most web browsers automatically accept cookies. However, your web browser can be set to allow you to control whether you will accept cookies or reject cookies, to notify you each time a cookie is sent to your browser, or to delete cookies that have already been set. If your browser is set to reject cookies, certain aspects of the Sites that are cookie-enabled will not recognize you when you return to the Site, and some Site functionality may be lost. The “Help” section of your browser may tell you how to prevent your browser from accepting cookies.
To find out more about cookies you may visit http://www.aboutcookies.org.
Under California law, once per year California residents may request a list of all third parties to whom we have disclosed certain personal information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and would like to receive such a list, please submit your request in writing to the address under the Contact Us section below.
For any such request, include the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state and zip code. Please provide enough information for us to determine if this applies to you. You must also attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, email, or by facsimile, and we are not responsible for notices that are not labeled or sent properly or that do not have complete information. Please allow up to thirty (30) days for a response.
Ichnos does not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information, as defined under Nevada law, please contact us as set forth in the Contact Us section below.
Access, Revision, Deletion
Under applicable privacy law (e.g., European data privacy law), you may have a right to request a copy of information about you held by Ichnos. You may also have the right to revise, correct, or delete such information. Your rights to such information may be subject to limited legal and regulatory restrictions.
Opting In / Permission to Contact You
Ichnos and our Service Providers will use the Personal Information we collect to respond to your inquiries and/or to send you information/newsletters, fulfill e-mail messaging programs, and notify you about new content or services on our Sites. Your request for information or services is also known as “opting in” to receive communications. By opting in to Ichnos e-mails, you also agree to the use of e-mail analytics (described below).
If you decide you no longer wish to receive promotional e-mail communications from Ichnos, you may opt out or “unsubscribe” at any time by using the contact information below or following the opt-out instructions contained in promotional email communications from Ichnos. You may opt out of other types of promotional communications by contacting us through one of the methods described under “Contacting Ichnos” below. If you opt out of receiving promotional communications from Ichnos, you may continue to receive non-promotional communications, such as information about safety warnings or changes to savings programs in which you are enrolled. If you have opted out of promotional Ichnos communications and subsequently request information from Ichnos, Ichnos will contact you to answer your request.
Objection to Processing and Additional Rights
Under applicable privacy law (e.g., European data privacy law), where Ichnos relies on legitimate interests or public interest to process information, and where Ichnos conducts direct marketing, individuals can formally object to processing of their information for these purposes (in addition to the “Opting In / Permission to Contact You” above). Individuals should clearly state “objection to processing” when contacting Ichnos to exercise this right to objection.
In certain circumstances, you have the additional rights to restrict aspects of the processing of your information or ask for a copy of your data to be provided to you, or a third party, in a digital format.
Rights of European Individuals to Complain to Data Protection Authorities
In the event that any individual located in the EEA countries or Switzerland believes that Ichnos has processed information in a manner that is unlawful or breaches his/her rights, or has infringed the “General Data Protection Regulation”, such individual has the right to complain directly to the applicable Data Protection Authority. Without limiting any rights to complain directly to an authority, Ichnos is committed to protecting Personal Information, and complaints may be made directly with Ichnos.
Questions Regarding Your Personal Information
If you have any questions or concerns about the way your Personal Information is used and handled, or would like to update or remove your Personal Information, please send your request to the address under the Contact Us section below or e-mail email@example.com.
Ichnos processes information to identify applicants, and assess job applications and for other human resources processes necessary for evaluating and considering job applications. The information processed may include information such as your job title, education information, professional qualifications, work experience, publications and scientific activities, professional networks, programs and activities in which you participated. Ichnos may process further information, such as government-issued identification number, tax status, bank account details, details of any known disability/workplace accessibility needs, background information, travel and expenses, performance management, emergency contact details, compensation, hours of work, holidays and benefits related information.
Ichnos processes the information of patients that use its treatments and services, as well as participants in Ichnos clinical trials. Ichnos may also have access to patient information through agreements with third parties (e.g., genetic data). In these instances, our Personal Information will be de-identified and replaced with a code. The coded study data will only be used for study-related purposes as well as the follow-up of the safety and the effectiveness of the study medication if necessary. Only authorized study staff, Ichnos’ personnel or third parties which help Ichnos with the conduct of the study will have access to the data. Ichnos may transfer the coded study data outside your country (e.g., to the United States) in order to process or to submit them to competent authorities.
Ichnos will not have access to the names or contact details of patients and trial participants, and does not attempt to directly identify individuals. You should contact your healthcare professional or the clinical trial site for trial participants to learn more about how your information is processed. Ichnos will process key-coded information about patients and trial patients – which may be one or more of, year of birth, initials or randomly selected unique identifier. Associated to this key coded data might be information relating to physical and psychological health, dietary information, ethnicity, sexual orientation, health- and safety-related information and other medical information. Information is collected from clinical trials and may include special categories of personal data.
Ichnos may also share de-identified information collected during the study with scientists outside of Ichnos for further clinical research in the interest of public health.
For individuals below the age of 18, the information will be processed in accordance with applicable laws and not be processed without the previous authorization of the parent or legal guardian.
Ichnos Sites are not directed to, nor do we knowingly collect information from, children under the age of 13. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at the contact information listed below.
Ichnos takes reasonable precautions to keep all information obtained from visitors to its Sites secure against loss, misuse, and unauthorized access, disclosure, alteration, or destruction, including encrypting Personally Identifiable Information during the transmission of such information. Nevertheless, Ichnos makes no guarantee as to the security of your Personal Information and disclaims to the fullest extent permitted by law all liability and damages caused by its loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please be aware that there is always some risk involved when submitting data over the Internet. We recommend that you take all available precautions to protect Personal Information you submit to Ichnos.
Keep in mind that any passwords, ID numbers, or other special access numbers you might use to access any part of the Sites are your responsibility, so you should safeguard them carefully. You should take steps to ensure that the computer you are using is adequately secured and protected against malicious software. Without adequate security measures (e.g., secure web browser configuration, up-to-date antivirus software, personal firewall software, no usage of software from dubious sources) there is a risk that the data and passwords you use to protect access to your data on the Sites could be disclosed to unauthorized third parties.
If you believe any credentials you use to access the Sites have been compromised, please change them and let us know as soon as possible.
Ichnos will retain your Personal Information for only as long as is necessary for the specific business purposes for which it was collected. Information may be retained for a longer period where applicable laws or regulations require, or allow Ichnos to do so.
Ichnos Sciences Inc.
Attn: Corporate Communications
1 World Trade Center
76th Floor, Suite D
New York, NY 10007
Effective: October 15, 2019