Privacy Policy - APCER Life Sciences

1. OBJECTIVE

This privacy policy/ document, is intended to inform you on the types of information that is collected and recorded by APCER Life Sciences and how we collect, define, and use personal data that you provide, when using our websites and social media platforms or when relying on our services. We use Your Personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

This Privacy Policy will primarily help you understand:

The nature of information we collect from you
The sources from where your information is collected (Including the cases where personal data is not directly collected from you)
The purpose of collecting your information
The manner in which your information is collected, stored, used and processed
The rights that can be exercised by you

2. SCOPE

This Policy applies to all vendors, visitors, customers, and other individuals who provide their personal data to the Company and all such individuals who are hereinafter referred to as “Data Subject(s)”.

3. BASIC TERMS

Sr. No.	Terms	Definition
1.	Personal Data	Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
2.	Data Subject	A data subject is the individual whose personal information is being collected, held or processed.
3.	IP Address	An Internet Protocol address (IP address) is a logical numeric address that is assigned to every single computer, printer, switch, router or any other device that is part of a TCP/IP-based network.
4.	Data Controller	A data controller is a person, company, or other body that determines the purpose and means of personal data processing (this can be determined alone, or jointly with another person/company/body).
5.	Machine Readable Format	Machine-readable data, or computer-readable data, is data in a format that can be easily processed by a computer. Machine-readable data must be structured data. E.g.: word document, pdf document, excel sheet, etc.
6.	Data Processor	Data Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

4. ABBREVIATIONS

Abbreviation	Meaningful form
DPO	Data Protection Officer
TCP/IP	Transmission Control Protocol/ Internet Protocol

5. ROLES & RESPONSIBILITIES

Data Controller detail: APCER Life Sciences Limited
Suite 211, Dowgate Hill House, 14-16 Dowgate Hill, London EC4R 2SU
Data Protection Officer (DPO) Contact Details: We envisage protecting and safeguarding your personal data and in lieu of the same, our nominated representative is Dr. Vineet Kacker. Dr. Vineet Kacker can be reached at DPO@apcerls.com.
EU Representative: APCER has appointed Dr. Frank Laschewski to act as our EU representative based out of Germany. If you are based in the EU and wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR) or have any queries about your rights or general privacy matters, please email our Representative at eurepresentative@apcerls.com
EU Representative Contact Details: Promenade 7 (Kornelius-Center), 52076 Aachen, Germany
Supervisory Authority Details: Information Commissioner’s Office (“ICO”). Email address: casework@ico.org.uk

6. INTRODUCTION

APCER Life Sciences is committed to improving health in partnership with its clients. We bring together safety, medical, regulatory, and technology resources to ensure that patients receive the safest, most effective therapies possible.

APCER Life Sciences, Inc., US, APCER Life Sciences Limited, UK, APCER Life Sciences Limited, Hong Kong and APCER Life Sciences India Limited. (Collectively and individually APCER, “We” and/or “the Companies”) are committed to protecting and respecting your privacy.

This policy (together with our Website User Agreement, and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please carefully read this Privacy Policy, which describes the ways in which we collect information about individuals who visit this website (“Personal Data”), how we hold and use Personal Data and how we respect your privacy rights.

APCER undertake to adopt all measures to prevent the misuse of the personal data provided by you. Your data will only be processed when there are legal grounds for their processing. Thank you for using our services.

7. Data Collection

We may collect and process the following data:

7.1 Personal Data

Personal data is information that you or a third party provides concerning details of, for instance, your name, postal address, e-mail address, age, nationality, contact number which will be disclosed by completing one of our standard forms posted on our site

Personal data collected from our website (www.apcerls.com) when you apply for job, register for newsletter, through social media, customer support includes name, email ID, phone number, address, family details, nationality and country.

7.2 IP Addresses

If you log on to our website, we collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We use this information to provide a better browsing experience to the website.

7.3 Cookies

We may obtain information about your usage of our site by using a cookie file which is stored on your browser or on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. Some of the cookies we use are essential for the site to operate. If you continue to use our site, you agree to our use of cookies.

When visitors come to our site, third parties may place cookies on visitors’ browsers for targeted advertising purposes. You may avoid that by utilizing ad blocker on your browser. Or to opt out of receiving targeted advertising.

The types of data collected will include IP addresses, cookie identifiers, website activity and in the cases where customer fills out a form, it will include all field information filled out by the customer.

For more information please refer to our Cookie Policy.

For more details on how we use cookies, please visit our cookie policy available at: https://www.apcerls.com/cookie-policy/

7.4 Third Party Applications/ Plugins

APCER utilizes third-party applications/ plugins on its website for the purposes of marketing and optimisation of the website experience. Some of these third-party applications may track your activity on the website and capture details like IP address session id, location etc. for the purpose of analytics.

The processing of personal data by the third-party applications/plugins does not fall under the scope of this privacy policy. To understand and learn more about how the third party applications/ plugins process your personal data please refer to the list of third party applications/ plugins and their privacy policies:

Tools integrated with the website:

ZoomInfo Websights – IP tracking
CrazyEgg – User interface tracking for website UI improvement

In addition to the above, we have tracking pixels for:

Google Analytics – for overall website traffic tracking
Google Tags Manager – for form submission tracking (lead generation)
LinkedIn ads – for form submission tracking
AdRoll display ads and Taboola display ads – for re-targeting website visitors.

7.5 Link to other websites

Our website may contain links to other sites that are not governed by this Privacy Policy. Please review the destination websites’ privacy policies before submitting personal data on those sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.

8. USING THE DATA

We use the personal data we collect from you for a range of different business purposes and according to different legal basis of processing. The following is a summary of how and according to which legal bases we use your personal data:

We may use personal data:

To respond to your inquiries and fulfil your requests, such as to send you newsletters or marketing mailers, apply for job openings.
To send administrative information to you, such as information regarding the Services and changes to our terms and conditions, and policies.
To facilitate social sharing functionality
To improve the services that we offer
To deliver a better and more personalised service.
To process reports on adverse events
To carry out our obligations arising from any contracts we have entered into relating to your personal data

As we believe to be necessary or appropriate:
1. under applicable law, including laws outside your state or country of residence;
2. to comply with legal process and to prevent, detect, or suppress abuse, fraud, or criminal activity;
3. to respond to requests from public and government authorities and self-regulatory organizations, including public and government authorities and self-regulatory organizations outside your state or country of residence;
4. to enforce our terms and conditions;
5. to protect our operations, assets, or interests or those of any of our affiliates;
6. to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and

9. RETENTION AND STORAGE

We will retain your Personal data for the period necessary to fulfil the purposes outlined in this policy unless a longer retention period is required or permitted by law. For details on our retention Policy please contact our DPO at DPO@apcerls.com.

Rest assured, data will be deleted/destroyed/archived post the retention period as per the data destruction mechanism developed by APCER in accordance with applicable laws, industry best practices, regional sectoral guidelines and contractual arrangements.

10. DATA SUBJECT RIGHTS

As a customer and/or data subject, you may inquire and raise requests regarding the following:

How to access, seek correction and/or erasure of your personal data;
How to object to processing of your personal data;
How to request for restricting processing of your personal data; and
How to request for a copy of your personal data, or have a copy thereof sent to another controller, in a structured, commonly used and machine-readable format under the right of data portability

For your protection, we may only implement requests with respect to the Personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before acting on your request.

To raise a request under this section or for clarification regarding your rights as a data subject, please send us a request on the following email ID:

DPO@apcerls.com

While we envisage to comply with your request within 30 working days of receiving your requests, we might require some additional time depending upon the circumstances under which the request was made.

Objecting to Legitimate Interest/Direct Marketing: Any data subject whose personal data has been collected may object to personal data processed pursuant to APCER’s legitimate interest. In such case, APCER will no longer process their personal data unless APCER demonstrates appropriate overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defence of legal claims. Natural persons also may object at any time to processing of their personal data for direct marketing purposes. In such case, their personal data shall no longer be used for that purpose. In cases of direct marketing, natural persons will be able to fulfil such rights directly via an ‘Unsubscribe’ link or similar mechanism (e.g: device settings for push notifications)

Use of Services by Minors: APCER’s services are not directed towards minors. In case the personal data of a minor is collected without the oversight of their guardian/ parents then we request you to contact our DPO.

11. SECURITY OF PERSONAL DATA

Please note that all information you provide to us will be secured using strict procedures and security features to prevent unauthorized access, breach or leakage.

APCER endeavors to ensure that the data disclosed by you is as secure as possible. To that end, we have implemented a number of technical and organizational measures, which utilize to protect your personal data from unauthorized or unlawful processing and from unintentional loss, destruction or damage.

12. DISCLOSURE

We may disclose your information to any of our employees, officers, insurers, professional advisers, agents, partners, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy and for the purpose of providing services to you.

Your Personal data may be disclosed or transferred to the following entities. With the exception of our corporate affiliates and service providers, these entities are not controlled by us and Personal data disclosed to them is subject to the applicable entity’s privacy policy and security practices. Therefore, we encourage you to review the privacy policies of any entity whose products or services you purchase using the Services:

We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006
We may disclose your personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of the Companies, our customers, or others.
To our third-party service providers who provide services such as website hosting and webinars. The information we provide to third parties service providers is subject to confidentiality obligations and is intended to be used solely for the purpose(s) permitted thereby.
To identify you to anyone to whom you send messages through the Services. You may also choose to disclose your Personal data on chat, social media, blogs, and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose any information on the Services.
To a third party, in the event of any reorganization, 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.
As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your state or country of residence; (b) to comply with legal process and to prevent, detect, or suppress abuse, fraud, or criminal activity; (c) to respond to requests from public and government authorities and self-regulatory organizations, including public and government authorities and self-regulatory organizations outside your state or country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, assets, or interests or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

13. CROSS BORDER DATA TRANSFER

The data that we collect or are provided with may be transferred to and stored at a destination outside the European Economic Area (“EEA”) and the United States of America (“US”). It may also be processed by staff operating outside the EEA and the US who work for us or for one of our related companies and affiliates.

APCER will ensure that a legitimate transfer of your personal data takes place to a location abroad keeping in mind the transfer mechanisms mandated by applicable laws.

14. OTHER IMPORTANT INFORMATION

Corporate restructuring

In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal data, would be transferred to the surviving entity in a merger or the acquiring entity by use of appropriate technical and physical safeguards. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal data as set forth in this Privacy Policy. This Privacy Policy shall be binding upon APCER and its legal successors in interest

Questions and Queries

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to DPO@apcerls.com.