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Last updated on 11 October 2021
Mycovia Pharmaceuticals, Inc. (“Mycovia”) respects your concerns about privacy. We want you to understand the types of information we collect, how we use that information, how we secure it, and whether we share it. When you use our website (or any website operated by Mycovia), request information about our company or our products, make a safety report or product complaint, apply for a job, submit forms or send email to our company, including inquiries about becoming an investigator, or participate in a Mycovia-sponsored clinical trial (as a service provider, investigator, study coordinator, or data subject) (collectively, the “Services”), you agree to our collection, use, disclosure, and transfer of information as described in this policy, so please review it carefully.
If you have executed a contract with Mycovia or signed an informed consent document or given other explicit consent related to a Mycovia Services, where the provisions of such contract or consent conflict with the terms of this policy, the terms of the agreement or consent document shall control.
Information We Collect or Receive
We only collect, use, share, store, or otherwise process your personal information when we have an appropriate basis. For example, we may process your personal information as necessary to facilitate our business or in connection with providing the Services, including processing a job application, responding to your inquiry, or facilitating your participation in a clinical trial. We may also process your personal information when necessary to comply with legal obligations, such as regulatory requirements, or for purposes of pursuing legitimate interests, if doing so is consistent with your rights and appropriate to the context, such as providing products, services or information you have requested, responding to your questions or concerns, and conducting reasonable monitoring of our websites to prevent misuse and fraud. Additionally, in certain cases, you may provide your explicit consent for certain processing of your personal information, such as when you sign a contract, serve as an investigator, or participate in a clinical trial as a data subject. In those cases, we may process your personal information for any purpose disclosed to you at the time you provided your consent for such processing.
We generally collect or receive information in three ways: (1) you voluntarily provide information to us; (2) we collect information automatically, such as through cookies in our websites; and (3) other parties, such as agents of Mycovia, may provide information to us. Each of these methods is described in more detail below.
(1) Information You Provide
You may provide your personal information to us when you choose to use a Mycovia website, when you do business with Mycovia, when you make an inquiry, apply for a job, or submit forms to the company, or when you make a safety report, submit a product complaint, or participate in a Mycoviasponsored clinical trial. Because we change the offerings and features on our websites and other Services from time to time, the options you have in order to provide us with information also may change. The information you provide to us through our website may include your name, title, your contact details such as physical address and/or mailing address, your email address, telephone number, professional and employment-related information (including your practice name and specialty (if applicable)) and educational information, such as your resume, job title, education history, qualifications, cover letter, and any information you submit in connection with an application for employment through the Services, and any additional information you choose to provide us through the Services.
The following are some examples of situations in which you may provide information to us:
- Requesting information about Mycovia or any of our products;
- Making a product complaint, safety report, or inquiry;
- Participating in a Mycovia-sponsored clinical trial;
- Completing a survey or questionnaire for Mycovia;
- Requesting information related to an educational or research grant or submitting a grant application;
- Doing business with or soliciting business from Mycovia;
- Submitting employment applications or inquiries;
- Submitting general inquiries, or sending any information through our websites;
- Subscribing to Mycovia notifications or newsletters;
- Contacting us for any reason, such as by telephone or by email (including email sent through a Mycovia website or otherwise using any Mycovia email address).
(2) Information Collected Automatically When You Use Our Website
When you access a Mycovia website, whether by computer, mobile phone, or other device, the website automatically collects information using technologies such as cookies. Automatically collected data may include, without limitation, information regarding your:
- Geographical location and identification of your computer, mobile, or other device;
- Bandwidth use and system and connection performance;
- Operating system, browser type, and version numbers;
- Length of visit and page views;
- Referral source;
- IP address or other unique identifier for your computer, mobile phone, or other device; and
- Mobile carrier, if applicable.
(3) Information We Receive from Others
In some cases, other parties provide us with information about you, such as agents of Mycovia who organize and implement our services or clinical trials (or practices submitting inquiries through the “contact us” form on a Mycovia website). Our agents could include answering services, call centers, investigators, study coordinators, or other service providers who carry out functions related to Mycovia business or sponsored clinical trials. Mycovia will treat the information received from our agents and practices in accordance with this policy. In no circumstances will we or our agents process sensitive personal information about you, such as information about your health, race, ethnicity, national origin, political opinion, religious or philosophical beliefs, trade union membership, genetic data, or information about your sexual orientation or sexual life without your consent.
How We Use Your Information
For individuals using our call centers or involved with clinical trials (including trial subjects, their spouses/partners, caregivers, and relatives; healthcare providers, clinical investigators, the personnel, consultants, contractors, managers, and agents of investigative sites; research institutions), we may use your information for the following purposes:
- To evaluate products or product effects;
- To assure compliance with regulations and reporting to authorities;
- To send or receive correspondence or communications with you;
- To develop, deliver, and improve our products, services, and other offerings;
- For internal administrative and compliance purposes such as auditing and data analysis.
When You Pursue or Enter a Business Relationship with Mycovia
When you share personal information in pursuit or in furtherance of a business relationship with Mycovia, whether through the Services or otherwise (i.e. soliciting business, submitting a request to become an investigator, sending advertising correspondence or materials, or submitting a proposal) Mycovia may use your personal information for such purposes including, but not limited to:
- To communicate with you, respond to your offers or requests, or provide you with updates and information;
- To conduct evaluations of prospective agents, suppliers, or providers;
- To obtain proposals, cost estimates, and to enter, track, and archive contracts;
- To improve the quality of Mycovia business operations, products, or systems;
- To enable agents to perform certain activities on Mycovia’s behalf; and
- For internal administrative and compliance procedures, such as auditing and data analysis.
When you Visit our Website
When you visit or use any of our websites for any purpose, we use the information collected automatically from our websites to:
- Administer the Mycovia website and diagnose problems with web servers;
- Count website users, measure traffic, and analyze trends;
- Investigate security incidents;
- Improve content and the delivery and effectiveness of the Mycovia website for website users; and
- Understand referral sources and the effectiveness of advertisement and directory listings.
When you Submit an Employment Application or Inquiry
If you submit an employment inquiry or application, we may use the personal information you submit for our recruitment and hiring purposes, including processing your application and evaluating your qualifications.
How We Share Your Information
We may share your personal information with business partners or contractors, agents, service providers, and other third parties that perform services on our behalf and under our instructions. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. All service providers shall be under a contractual obligation to adhere to applicable privacy laws.
We may also disclose information about you for purposes described in the How We Use Your Information section above, including (i) to protect against malicious, deceptive, fraudulent, illegal, or other unauthorized activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity, (ii) to protect the legal rights, property, safety, and security of our organization, assets, workforce, users, clients, clinical trial subjects, and others, including to protect the physical safety and/or wellbeing of any individual, (iii) to conduct research, (iv) to comply with law, other legal and regulatory obligations, such as those related to clinical trials, taxation, litigation, audit, or investigation, industry standards, legal process, or law enforcement authorities or other government officials’ requests, (v) the event of a potential or actual material change to our business including a purchase, merger, joint venture, acquisition, bankruptcy, liquidation, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.
We store personal information for as long as we reasonably need it to fulfill the purposes for which it was collected. We will retain and use personal information as necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.
We provide you with choices about whether to provide us with personal information and whether it is shared. For example, when you provide information to us through a Mycovia website, we generally only ask you for personal information that is necessary to fulfill the purpose for which the information is requested. You can choose not to give us the personal information we request. However, in some cases, if you decide not to provide the personal information we request, we will not be able to respond to your request. In addition, we are required to seek your consent before we use your personal information for any purpose incompatible with the purposes identified in this policy. You may withdraw your consent given pursuant to this section at any time by sending an email to email@example.com. Any withdrawal of consent is only effective on a going-forward basis and will not impact processing we undertook while relying on your consent.
Other examples of your choices include:
- You can browse a Mycovia website without providing any personal information. We may collect some limited information automatically, as described above.
- You may change your browser settings or take other steps to block, manage, or delete cookies. In some cases, blocking or disabling cookies may cause a website not to work as intended and some features may not be available. Our sites do not respond to “do not track” browser signals at this time.
How We Protect Personal Information
We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. Generally, if you participate in a clinical trial as a data subject, Mycovia only receives information about you that has been pseudonymized or manipulated to replace information that identifies you with non-identifying information, and most identifying personal information is maintained at the clinical trial site and/or is processed on Mycovia’s behalf by its agents.
Transfers of Information
As part of our operations, we may transfer information about you to any jurisdiction where we do business. We will transfer your personal information for any of the purposes identified in this policy to our service providers that may be located outside of the jurisdiction where you are located. The laws in those jurisdictions may not provide the same level of data protection compared to the laws in your country. However, we will treat your personal information as subject to the protections described in this policy.
When we transfer personal information from the European Economic Area (“EEA”), United Kingdom, or Switzerland to another party located outside the EEA, United Kingdom, or Switzerland, we will rely on a legal framework that provides appropriate safeguards, which could include the standard contractual clauses, binding corporate rules or another framework deemed adequate by the European Commission.
A Mycovia website may include contact information, telephone numbers or links to websites, call centers, applications, and services operated by third parties, either on our behalf or on their own behalf, that are subject to their own privacy policies. We encourage you to review those privacy policies, which apply to the information collected by those websites, call centers, applications, and services.
Additional Privacy Rights and Obligations (EEA, United Kingdom, and Switzerland)
This section sets out rights applicable only to the personal information of individuals located in the EEA, United Kingdom, or Switzerland, and our obligations regarding their personal information. Mycovia is committed to maintaining accurate, complete, and current records of personal information. If you are located in the EEA, United Kingdom, or Switzerland, you may have the right to access and review your personal information, and to request that Mycovia amend, correct, or delete personal information that is inaccurate, incomplete, or outdated. To the extent consistent with applicable law, Mycovia will, on request, provide you with confirmation regarding whether Mycovia or any of its agents may be processing your personal information, and will take commercially reasonable steps to:
- Verify your identity before granting access to or making any changes to your personal information;
- Confirm that your personal information is being processed according to this policy; and/or
- Correct, update, amend, delete or otherwise remove any personal information found to be inaccurate, incomplete, or processed in a manner non-compliant with this policy.
If you would like to request access to or correction of your personal information, please submit your request by sending an email to firstname.lastname@example.org. Please include your name, email address, and postal address in your request, and describe specifically the information that you would like to access or correct so that we may respond appropriately and promptly. Mycovia reserves the right to charge a reasonable fee to cover costs for providing copies of personal information requested under this section. Although Mycovia will make a good faith effort to provide you with access to your personal information, there may be circumstances in which Mycovia is unable to provide access, including but not limited to:
- where the personal information is subject to legal privilege;
- where the provision of access would compromise the privacy or legitimate rights of others; or
- where the burden or expense of providing access is disproportionate to the risks to your privacy.
If you are located in the EEA, United Kingdom, or Switzerland then you have the right to restrict or object to our processing of your personal information. The right to restrict processing arises only in limited circumstances, for example, if you think we are processing inaccurate information. In addition, if we are required to restrict processing but the requirement is temporary, we may not be permanently obligated to adhere to your request. We will, however, let you know when the restriction is lifted. In cases where our basis for processing your information is the satisfaction of our legitimate interests, you may object to our processing. However, we will decline your request if our interest in continuing to process your information is sufficiently compelling to legally override your interest in the request, or our processing is necessary to establish, exercise, or defend a legal claim. To request a restriction or to object to processing, please submit your request by sending an email to email@example.com.
In cases where we process your personal information pursuant to your consent, you may contact us by email to firstname.lastname@example.org to request that your consent be withdrawn. Individuals residing in the EEA, United Kingdom, or Switzerland or whose personal information is processed by Mycovia also have the right to obtain their personal information so they can transfer it to another party, or ask us to do so on their behalf, which we will do when technically feasible. This right is limited, and only arises when our processing of your information is automated and based on your consent or an agreement with us. To exercise this right, please submit your request by sending an email to email@example.com.
Individuals residing in the EEA, United Kingdom, or Switzerland may make additional inquiries to Mycovia’s data protection representative using the contact details below:
(for Mycovia Pharmaceuticals, Inc.)
Prague 15000 Czech Republic
VeraSafe Ireland Ltd.
(for Mycovia Pharmaceuticals, Inc.)
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P Ireland
Individuals residing in the EEA or Switzerland also have the right to lodge a complaint with a supervisory authority established in their country.
This policy may be updated periodically to reflect changes in our personal information practices or relevant laws. We will indicate at the top of this policy when this policy was last updated. Please review this policy every time you access or use our website to make sure that you have reviewed the most recent version.
How to Contact Us
Mycovia encourages individuals covered by this policy to raise questions, concerns or complaints by sending an email to Mycovia at firstname.lastname@example.org or, if you reside in the EEA, United Kingdom, or Switzerland, by using the contact details provided above.