Privacy Policy

This Privacy Notice (“Privacy Notice”) describes the data that we collect about you on the website from which you linked (“Site”); how we use and disclose that data; how we protect it; and the choices you may make with respect to it.

Personal Data

“Personal Data” is data that identifies you as an individual or relates to an identifiable individual. We collect Personal Data in various ways on our Sites in connection with your inquiries, and automatically when you browse our Sites.

We may request basic Personal Data when you use a Site; if you are an HCP, we may request additional Personal Data.

Personal Data that we may request includes:

Name
Contact details (such as postal address, telephone numbers, email address)
Your interests (such as health conditions and topics about which you request information through the Site or indicate interest)

If you are an HCP, we also may request additional data related to our professional interaction with you:

Professional biography/credentials
Data related to your licenses, specialties, professional affiliations, publications, credentials, and other professional achievements
Data related to your organisation
Adverse event data
Data related to your use of our products, your interactions with us, and services for those you care for

We may also collect Personal Data from other sources, including data companies, publicly accessible databases, joint marketing partners, social media platforms and other third parties.

When you are asked to provide Personal Data, you may decline. But if you choose not to provide data that is necessary to for us to provide requested services, we may not be able to provide you those services.

If you provide or permit us to collect any Personal Data relating to another person, you are telling us that you have the authority to share that data and to permit us to use the data as described in this Privacy Notice.

How we use Personal Data

We use Personal Data in order to:

Provide Site functionality and fulfil your requests when we have a contractual relationship or a legitimate interest.

Site functionality and fulfilling your requests includes:

To provide customer service to you.
To respond to your inquiries and fulfil your requests and complete your transactions.
To send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest to you.
To facilitate social sharing functionality.
To allow you to send messages to another person, such as a colleague, caregiver or friend or patient.
Provide personalised services when we have your consent or a legitimate interest in providing you with information of interest to you.

Personalised services include:

To better understand you and personalise our interactions with you.
To analyse or predict our users’ preferences in order to identify aggregated trend reports on how Cellen Biotech Ltd. digital content is used.
To analyse or predict your preferences in order to improve our interactions with you, i.e., to deliver you the content, products and offers (via our Site, emails or digital tools) that we believe will be relevant to your professional interests.
Engage with you as an HCP when we have a contractual relationship or a legitimate interest.

Engaging with you as a health care professional includes:

To verify your eligibility to access certain products, services and data that may be provided only to certain licensed HCPs.
To interact with you based on your professional expertise and opinion by digital or other means.
To involve you in programs/panels of healthcare professionals.
To reach out to you for your professional expertise, for example, in the context of surveys relating to products or services of a Cellen Biotech Ltd. entity or its business partner.
To collaborate with you on medical events, publications, or advisory meetings.
Allow you to participate in special programs, activities, events, or promotions as part of our contractual relationship with you or where we have a legitimate interest. In these cases, we may use your Personal Data in additional ways disclosed as part of these special program, activities, events or promotions.
Operate our business to comply with our legal obligations and to meet our legitimate interests in maintaining our business.

Our business activities include:

To conduct data analysis and audits.
To identify usage trends in the use of our Sites and analyse the effectiveness of our communications.
To detect, prevent, investigate fraud and including (cyber) security monitoring and prevention.
To develop, enhance, improve or modify our products and services.
To validate your ability to access or use certain products or services.
To better understand how our products and services impact you and those for whom you care.
To track and respond to concerns, including engaging in regulatory monitoring and reporting obligations related to adverse events, product complaints and patient safety.
To operate and expand our business activities.

We may aggregate the Personal Data that you and other Site users provide. If we do, we may use and disclose such aggregated data for any purpose. Aggregated data does not personally identify you or any other individual.

How we use and disclose Personal Data

We disclose Personal Data as to our third party service providers, to provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.

We also use and disclose your Personal Data as we believe to be necessary or appropriate:

To comply with applicable law and our regulatory monitoring and reporting obligations (which may include laws outside your country of residence), to respond to requests from public and government authorities (which may include authorities outside your country of residence), to cooperate with law enforcement, or for other legal reasons.
To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

In addition, we may use, disclose or transfer Personal Data to a third party in connection with any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Marketing Controls

If you no longer want to receive marketing communications from us, contact us via our contact us form. In your request, please provide your name and email address. If you opt out of receiving marketing communications from us, we may still send you important administrative messages, from which you cannot opt out.

Individual Rights

If you would like to request to review, correct, update, suppress, restrict or delete Personal Data that you have provided to us through the Site, or if you would like to request to receive an electronic copy of such Personal Data for purposes of transmitting it to another company, you may contact us. We will respond to your request consistent with applicable law.

In your request, please tell us what Personal Data you would like to have changed, whether you would like to have it suppressed from our database, or otherwise let us know what limitations you would like to put on our use of it. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain Personal Data for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

Data Security

We seek to use reasonable organisational, technical and administrative measures to protect your Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

Retention Period

We will retain your Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Notice. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Site to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to the enforcement of the Site Terms of Use, applicable statutes of limitations, litigation or regulatory investigations).

Cross-Border Transfer

The data we collect through the Site may be stored and processed in any country in which we engage service providers, including in the U.S. Note that we only work with service providers that have the highest standards when it comes to data privacy and security (e.g: Privacy Shield).

Third-Party Services

This Privacy Notice does not address, and we are not responsible for, the data collection, use, disclosure or security practices, or other practices, of any third party, including any third party operating a service to which the Site links. The inclusion of a link within the Site does not imply our endorsement of the linked service.

Use by Minors

The Site is not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Data from such individuals. If you are under the relevant age of consent in your jurisdiction, you will need your parent’s or legal guardian’s permission to use the Site. Please consult with your parent or legal guardian before using the Site. If you are providing us with Personal Data of individuals under the age of sixteen (16), you represent that you have the appropriate authority to do so, and that you can demonstrate such authority to Cellen Biotech Ltd. upon request.

Updates

From time to time, we will update this Privacy Notice. Any changes will become effective when we post the revised Privacy Notice on the Site. This Privacy Notice was last updated as of the “Last Updated” date shown above.

The company responsible for collection, use and disclosure of your Personal Data under this Privacy Notice is

Cellen Biotech Ltd.

Registered Office is CMS Cameron McKenna Nabarro

78 Camron Street, London EC4N 6AF

If you have questions about this Privacy Notice, or if you would like to request to exercise any individual rights, please contact us at contact@cellenhealth.com, or write to the following address:

2, 77 Smith Square, Fulham Palace Rd, London W6 8AF

Cookies are a standard feature of websites that allow us to store small amounts of data on your computer about your visit to our Site. Cookies help us learn which areas of the Site are useful and which areas need improvement.

Please refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers. Please be aware that if cookies are disabled, your experience on the Site may be diminished, and not all features of the Site may operate as intended.

We may also use technologies similar to cookies, such as:

Pixel Tags. Pixel tags (also known as web beacons and clear GIFs) are used to, among other things, track the actions of users of the Site, measure the success of our marketing campaigns, and compile statistics about usage of the Site and response rates.

Google Analytics. Google Analytics is a service provided by Google, Inc. (“Google”). We use Google Analytics to collect anonymised statistics in order to improve the Site.

Browser or Device Information. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Site you are using. We use this information to ensure that the Site functions properly.

To the extent any Personal Data is collected through cookies or similar technologies, the other sections of this Privacy Notice apply.