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FARON’S PRIVACY NOTICE

Purpose of this Privacy Notice (“Notice”) is to provide information how, Faron Pharmaceuticals Ltd (“Faron”; incorporated and registered in Finland with business identity code 2068285-4) or its group companies (“we”) process as a data controller your personal data when you visit this website (“Site”) or when you contact or request information from Faron in other ways as a result of your relationship with us.

Please also note that this Notice is not applicable to any personal data processed and controlled by third parties, for example through third-party websites owned or operated by another party than Faron. Furthermore, this Notice is not applicable to individual persons who apply to work or already work at Faron or any personal data processed in clinical studies. Faron’s Privacy Notices for job applicants and employees are available in separate systems when logging in and if you want more detailed information in any relation to how specifically your personal data is being processed, please contact Faron by using the contact information provided in this Notice.

What personal data do we collect and how do we process it?

All data related to an identified or identifiable person are personal data and for as long as the data can be used to identify persons directly or indirectly (such as by combining an individual data item with some other piece of data that enables identification) or restore that data to an identifiable format, they constitute personal data.

At times, you may be asked to provide your personal data via this Site, for example, if your register on this Site in order to gain access to specific content, attend a hosted event (such as a general meeting) or a webcast, respond to a survey, request communications about specific areas of interest or when we need to collect your personal data (e.g., contact details) for possible contractual relationships and under the terms of a contract we are going to enter with you.

And when you visit our Site, it saves cookies which enable our website to function and enable electronic services. Detailed information on the cookies we use and the purposes for which we use them can be found in our Cookie Notice when visiting our Site.

We may also collect publicly available data about you through other channels like other websites or interactions with third parties in order to analyse information related to Faron.

Categories of personal data which we process (see below) may vary depending on a channel you are using and your choices (privacy settings):

  • Identity Data i.e., information necessary for identifying persons includes e.g., your name, occupation, date of birth and gender;
  • Contact Data i.e., administrative data related to the job/task includes e.g., your place of work, work address, work email address and telephone number;
  • Financial Data includes e.g., your shareholding details and transactions with us;
  • Technical Data i.e., cookies on the Site to improve the user experience and to target online advertising (includes e.g., IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site; please see further information about cookies in our Cookie Notice).
  • Interaction Data includes e.g., information on our meetings and communications with you and the covered talking points;
  • Profile Data includes e.g., your experience, interests, preferences, feedback and survey responses and how you use our products and services and
  • Marketing and Communications Data includes e.g., your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also process other personal data voluntarily provided by you.

The main purposes of processing your personal data by us are:

  • to build, manage and develop our relationship with you, which may include e.g., event management;
  • to administer, measure and protect our business;
  • to research, develop and deliver relevant products and services and
  • to improve our products, services, marketing, our customer relationships, and your experiences.

Lawful basis for processing personal data

We will use your personal data on lawful grounds and we will use your personal data in the following circumstances:

  • When it is necessary to perform our obligations under contract with you or we are about to enter into one with you.
  • When it is necessary for our legitimate interests (or those of a third party), for example where there is a relevant and appropriate relationship between you and us, and your interests and fundamental rights do not override those interests. Processing of personal data for marketing purposes or developing our business, for instance, may be regarded as carried out for a legitimate interest.
  • When we need to comply with a legal or regulatory obligation.
  • Generally, we do not rely on consent as a legal basis for processing your personal data other than in particular cases like e.g., when using direct marketing to you or when you have given your consent to cookies of which you can find further information in Cookie Notice. You have the right to withdraw your consent according to Cookie Notice or each marketing message containing instructions how to opt out.

Recipients of personal data

Personal data may be disclosed between Faron’s group companies for purposes compatible with the processing purposes set out above in this Notice, and some of these entities are located outside of EU/EEA countries.

We may also disclose personal data to the extent permitted and required by law to authorities.

Your Personal Data may be processed by third-party service providers acting on our behalf and under our instructions to support the deployment, administration and hosting of the Site and our other IT systems and to provide consultancy, banking, legal, insurance, accounting, market research and other services. These third parties are providing their support to us as data processors, and we have agreed on the appropriate functions required by applicable data protection legislation and entered the personal data processing agreement with this service providers.

Data transfers out of the EU/EEA

Sharing your personal data within our group of companies will involve transferring your personal data out of the European Union (EU), European Economic Area (EEA) or Switzerland (collectively, “Europe”). Faron and its group companies have agreed an intra-group data processing agreement which is based on the EU Standard Contractual Clauses to ensure we shall comply with our legal and regulatory obligations in relation to processing of personal data.

In addition, many of our external third parties are based out of the Europe and also processing of your personal data by these sub-processors involve data transfer out of Europe. Whenever we transfer your personal data out of Europe, we ensure that sufficient level of data protection is maintained through appropriate safety measures, e.g., the EU commission’s model clauses (SCCs; Standard Contractual Clauses) or according to the adequacy decisions set by the European Commission or using some other transfer mechanism in accordance with applicable legislation. More information of such international data transfers and applied safeguards may be received by using the contact details provided in this Notice.

How long do we keep your personal data for?

We will only retain your personal data for as long as necessary for the purposes of use we collected it for. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, the laws that apply and whether we can achieve defined purposes through other means without processing personal data. For more information regarding the retention times, you may contact us by using the contact details provided in this Notice.

Data security

Faron processes personal data securely and according to applicable laws. It has protected the data appropriately in technical and organisational terms. The data are stored appropriately on secure servers with technical data security that is controlled by different means and the access to the data is managed by role-based management of access rights.

Your rights with respect to your personal data

Under certain circumstances, you may have the following rights under data protection laws in relation to your personal data:

  • Right to access i.e., to receive our confirmation whether your personal data is processed by us or not. If we as a data controller process your personal data, you have the right to receive information in this Notice about personal data processing in general and a copy of your personal data being processed or already processed. Request for access to your personal data may be presented to us by using the contact information provided in this Notice.
  • Right to rectification, erasure and restriction of data entitles you to have any such personal data that is inaccurate, outdated, unnecessary or contrary to the purposes of data processing corrected or erased. You have also the right to demand that we as a data controller restrict the processing of your personal data or otherwise oppose the processing of your data. Requests concerning these rights may be presented to us by using the contact information provided in this Notice. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Right to object personal data processing when processing is based on our legitimate interest only, you are entitled to object to the processing of your personal data on grounds relating to your situation. You may send your request to object the processing by using the contact information provided in this Notice. In this request, you shall give reasons why you are objecting to the processing of your data (e.g., you feel it impacts on your fundamental rights and freedoms). Faron may decline the request on statutory grounds. You also have the right to opt out of receiving direct marketing communications from us.
  • Right to data portability of your personal data to be transferred to you or to a third party assigned by you in machine-readable format. Note that this right only applies to information which you by yourself provided about you to us.
  • Right to cancel prior consent when processing of personal data is based on consent, you have the right to cancel your consent. However, this will not affect any processing carried out before you withdraw your consent, and the cancellation of your consent does not affect the lawfulness of processing performed based on the consent prior to its cancellation.
  • Right to lodge a complaint if you consider that we as a data controller does not follow the applicable data protection regulations, you have the right to lodge a complaint with the competent data protection authority.

If you would like to exercise your rights set out above, please contact us by using the contact details set out below. Generally, Faron does not charge the data subject/you for using the data subject’s rights presented in this Notice, but Faron may, at its sole discretion, (a) refuse to fulfil; or (b) charge a reasonable fee for fulfilling of several similar consecutive data subject’s access requests that are manifestly unfounded or excessive. Faron is also entitled to decline requests on statutory grounds.

We may need to request specific information from you to help us confirm your identity and you shall attach the following information to your request: information that can be used to identify you (such as e.g., full name, email address or similar), information in which role you are contacting us (e.g., consultant), information about which of the data subject’s legal rights mentioned above you wish to use.

Contact details of data controller

If you have any questions regarding this Notice or wish to exercise your rights set out in this Notice, please contact us by sending an email to privacy@faron.com or by sending an ordinary mail at:

Faron Pharmaceuticals Ltd
Attn: Legal
Joukahaisenkatu 6
FI-20520 Turku
Finland

As at the date of Notice the group companies include:

Faron Europe GmbH incorporated and registered in Switzerland with enterprise identification number CHE-426.959.656 whose registered office is at c/o Wadsack Zug AG, Bahnhofstrasse 7, 6300 Zug, Switzerland.

Faron USA LLC incorporated and registered in Delaware with file number 6713226, address is 22 Wharf Road, 7th floor, Boston MA 02210, USA.

Changes to this Privacy Notice

Faron reserves the right to change and update this Notice as required. Please check this page from time to time to inform yourself of any changes in this Notice.

Page Updated on : 11 July 2023

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