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Safety InformationPrescribing Information

PRIVACY POLICY

Introduction

Cycle understands the fundamental importance of privacy, data protection, and security. We take your privacy seriously and are committed to safeguarding your personal data.

This Privacy Policy (“Privacy Policy”) informs you how Cycle collects, processes, transfers and protects personal data. Cycle Pharmaceuticals Ltd is a company registered in England and Wales with company number 07933058 (“Cycle/we/us”). Registered office address: Bailey Grundy Barrett Building, Little St.Mary's Lane, Cambridge, England, CB2 1RR. Cycle is a private limited company acting on behalf of itself and its subsidiaries.

In this Privacy Policy, “personal data” means any information which on its own or combined with other information relates to and identifies (directly or indirectly) a living individual.

Scope

This Privacy Policy applies to all Cycle companies as well as Cycle websites, domains, services, applications, and products.

This Privacy Policy does not apply to third-party applications, websites, products, services or social media platforms that may be accessed through links that we provide to you. These sites are owned and operated independently from us, and they have their own separate privacy and data collection practices. Any personal data that you provide to these websites will be governed by the third party’s own privacy policy. We cannot accept liability for the actions or policies of these independent sites, and we are not responsible for the content or privacy practices of such sites.

Types of Data We Collect and How We Collect It

Data you provide

When you interact with us, we collect and process personal data from your online activity, your use of devices, products or services. This data can be used to help you register for updates, deliver products or services to you or improve the way we or our products work with you. This data may include:

  • Update information such as your name, title, date of birth, gender, company, profile photo, email address, mailing address and phone number.
  • Payment information such as your billing address, credit card, debit card or other payment method.

  • Other information such as your occupation, employment details, academic institution details and residential address.

Data we automatically collect

When you visit a Cycle website we automatically collect and store information about your visit using browser cookies (files which are sent by us to your computer) or similar technology which we can access when you visit a Cycle website in future. For further information regarding our use of cookies please refer to our Cookie Policy.

We also process information when you use the Cycle Website or services. This information includes IP addresses, login information, device IDs, time stamps, authentication records, location information, carrier service used, signal strength, the origin, destination, type and quantity of traffic passed and other operational data.

Data we collect from third parties

We may receive your personal data from third parties such as social network platforms, partners and other sources. This information is not collected by us but by a third party and is subject to the relevant third party’s own separate privacy and data collection policies. We do not have any control or input on how your personal data is handled by third parties so if you have any questions you should contact the relevant third party for further information about your personal data.

How We Use Personal Data We Collect

We collect and use personal data about you with your consent to provide, maintain, and develop our products and services and understand how to improve them.

  • provide you with alerts, products, promotions, services, newsletters, invitations and other information about health topics and disease states in accordance with your preferences;
  • respond to correspondence that we receive from you (in particular with regard to a report of an adverse event);
  • provide you with additional information that might be of interest to you;
  • operate our business;
  • improve our services and products;
  • deliver our products and services;
  • process, complete and fulfil your requested transactions;
  • identify you and manage any accounts you hold with us;
  • customize our website and its content to your particular preferences;
  • notify you of any changes to our website or to our services that may affect you;
  • help diagnose problems with the servers.
  • host discussions, blogs and information to encourage knowledge sharing and effective collaboration;
  • investigate and prevent security incidents such as breaches, attacks and hacks;
  • aggregate your information in an anonymised form to generate usage statistics;
  • display content and advertising, including third-party advertising, that we believe might be of interest to you;

Where we process your personal data to provide a product or service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in our legitimate interests to provide products and services and to maintain our relationship with you and to protect our business for example against fraud. We will seek your consent to send you direct marketing.

Process and storage

We store and process data on servers in the European Economic Area (EEA). However, your personal data may also be transferred to and processed in regions including North America, Africa and Asia Pacific. Laws protecting your personal data may be different to the place where you live. We will take appropriate steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy as well as applicable data protection law.

Sharing and Disclosure

We will share your personal data with third parties only in the ways set out in this Privacy Policy or set out at the point when the personal data is collected. We consider your personal data to be a vital part of our relationship with you. We do not sell your personal data to third parties, including to third-party advertisers.

Cycle Subsidiaries

We may share your information across the Cycle corporate group in order to provide, maintain and develop our products and services.

Legal Requirement

We may use or disclose your personal data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical to do so, we will tell you in advance of such disclosure.

Service Providers and Other Third Parties

We use a variety of third-party service providers, independent contractors, agencies, approved distributors and consultants to deliver and help us improve our products and services. Service providers may be within or located outside the EEA. We may share your personal data with marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others but only to maintain and improve our products and services.

Data Aggregation and Analytics

We may collate your personal data you provide to us or we collect and use it anonymously for analytics, benchmarking and to effectively monitor the website and improve your user experience.

Security

We take reasonable steps to safeguard the personal information that you provide to us. You acknowledge that the use of the internet is not entirely secure. For this reason Cycle cannot guarantee the security or integrity of any data transferred over the internet, and the information that you provide to us is at your own risk.

To the extent permitted by law, Cycle may review, scan or analyse communications for fraud prevention, investigation, regulatory compliance, risk assessment, research, product development, and customer support purposes.

We use industry-standard encryption technologies when transferring and receiving personal data, and network access control technology to limit access to the systems on which personal data is stored, and we monitor for possible vulnerabilities and attacks.

If you become aware that there has been a breach in security of any of the personal data that we store or that is stored by our third-party service providers, please contact us via the instructions provided in the Contact Us section below.

Retention

We will only retain your personal data for as long as necessary for the purpose for which that data was collected and to the extent required by applicable law. When we no longer need personal data, we will remove it from our systems and / or take steps to anonymise it.

Your rights

You have the following rights (if applicable):

Access

You have the right to request a copy of the personal data we are processing about you.

Rectification

You have the right to have incomplete or inaccurate personal data that we process about you rectified.

Deletion

You have the right to request that we delete personal data that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

Restriction

You have the right to restrict our processing of your personal data where you believe such data to be inaccurate; our processing is unlawful; or if we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish us to delete it.

Portability

You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal data which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.

Objection

Where the legal justification for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.

Withdrawing Consent

If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge such as where you wish to opt out from marketing messages that you receive from us. If you wish to withdraw your consent, please contact us at dataprotectionoffice@cyclepharma.com.

You can make a request to exercise any of these rights in relation to your personal data by sending the request by mail to Data Protection Office of Cycle Pharmaceuticals Ltd, Bailey Grundy Barrett Building, Little St.Mary's Lane, Cambridge, England, CB2 1RR or email to dataprotectionoffice@cyclepharma.com. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.

Children’s Privacy

We do not knowingly collect or solicit personal information from anyone under the age of 18 without prior parental or authorized caregiver consent. If you are under 18 please do not attempt to register for the services on our website or send any personal information about yourself to us. To the extent that you are under 18, please have your parent or authorized caregiver register for the services on our website. If we learn that we have collected personal information from a child under age 18 without obtaining prior parental or authorized caregiver consent we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us personal information, please contact us at dataprotectionoffice@cyclepharma.com.

Changes

We may modify this Privacy Policy at any time. If we make changes to this Privacy Policy then we will post an updated version of this Privacy Policy on our website. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Us

To contact us, please email dataprotectionoffice@cyclepharma.com or write to us at:

Data Protection Office
Bailey Grundy Barrett Building
Little St.Mary's Lane
Cambridge
Cambridgeshire
England
CB2 1RR

Complaints

If you have a complaint about this Privacy Policy or any element of your personal information that we hold then please contact us at the above address. If you are not satisfied, then you have the right to lodge a complaint with your local data protection authority.

If you are based in, or the issue relates to, the UK, you can contact the Information Commissioner’s Office at the following address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
England
SK9 5AF

Alternatively, you can use an online form via the Information Commissioner’s website.

If you are based in, or the issue you would to complain about took place elsewhere in the EEA, please visit this website for a list of local data protection authorities in other EEA countries.

If you are based in, or the issue relates to, the US, you can contact the Federal Trade Commission at the following address:

Federal Trade Commission, Bureau of Consumer Protection, Division of Privacy and Identity Protection
Federal Trade Commission (Headquarters)
600 Pennsylvania Avenue, NW
Washington, DC 20580

Alternatively, you can use an online form via the Federal Trade Commission website.

If you are based in, or the issue relates to, Canada, you can contact the Federal Trade Commission at the following address:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Québec
K1A 1H3

Alternatively, you can use an online form via the Office of the Privacy Commissioner of Canada website.

GL-0026 Date of Production: October 2019
Copyright © 2019 Cycle Pharmaceuticals Ltd. All rights reserved.

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