Privacy and Data Protection Policy (“Privacy Policy”)

If you live in the EEA or the UK and perform a clinical role, such as a clinician or investigator, within one of Chinook's sponsored clinical trials and you provide SanReno with any personal information outside of this role, please see our Partner – Clinician Privacy Notice (URL); if you live in the EEA or the UK and participate in a clinical trial sponsored by Chinook and you provide SanReno with any other personal data outside of a clinical trial, please see our Partner Privacy Notice for EEA and UK Study Participants (URL).

 

• 1. Privacy Statement

SanReno is aware that the security of your private information is an important concern. We take the protection of your personal data very seriously. Therefore, we would like you to know what data we maintain and what data we discard. With this privacy statement, we would like to inform you about our security measures.

This Privacy Policy applies to personal information processed by us. We only collect information you chooses to provide, e.g., information provided through registrations, surveys and your use of our online and offline services. To make this Privacy Policy easier to read, our websites, applications, surveys and other offerings we provide to you are collectively called “Services”.

For information on how to contact us, please refer to “Contact Us” section below.

• 2. Pledge on privacy

The term "Personal Data" as used in this Privacy Policy refers to information such as your name, birth date, e-mail address, mailing address, or telephone number that can be used to identify you. Generally, we will only process your Personal Data as described in this Privacy Policy. However, we reserve the right, to conduct additional processing to the extent permitted or required by law, or in support of any legal or criminal investigation.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

• 3. Collection of Information

The categories of information we collect is in connection with your inquiries and purchases. For example, by choosing to use our Services in a way in compliance with requirements of applicable laws, you may choose to provide your name, contact information, health, insurance and/or financial information in connection with a promotion or a patient assistance or support program. The information we collect can be detailed below:

• 3.1 Information You Provide to Us Directly

We may collect information that you provide to us such as your name, email address, phone number, or mailing address. Such collection may occur in your creation of account, your inquiries to us., eg, request information about our Services, request patient, customer or technical support, apply for a job, and your participation into events such as conferences, trade shows and other events.

• 3.2 Information Collected Automatically

We may collect personal information automatically when you use our Services:

• ⅰ) Automatic Data Collection.  We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services.

• ⅱ) Location Information. We may collect precise location information to better assist you in the use of our Services.

• ⅲ) Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

3.3 Our uses of these Technologies follows the below principles:

• ⅰ) Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;

• ⅱ) Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services;

• ⅲ) Functionality-Related.We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

3.4 Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations, but only with your prior written approval. When you use such third-party services, communication data are exchanged between you and the respective provider for technical reasons. Since we have no control over data collected and processed by third parties, we are not in a position to provide binding information regarding the scope and purpose of such processing of your personal data.

• 4. Undertaking and Consent

You consent to the collection and use of information by SanReno. You also acknowledge that SanReno may periodically change, modify, add or remove or otherwise update this Privacy Policy at its discretion, without prior notification. However, we will always handle your Personal Information in accordance with the Privacy Policy that was in effect at the time of collection. It is our intention to post changes to our Privacy Policy on this page so that you are fully informed concerning the types of information we are gathering, how we use it, and under what circumstances it may be disclosed.

• 5. Voluntary Provision

As mentioned above, you can always choose not to provide your Personal Information to SanReno, but by doing so you may be prevented from being able to retain the business opportunity with SanReno. All information submitted in registration shall be real and effective.

• 6. Use

We use your information for a variety of business purposes as described below.

• ⅰ) To manage your account and information;

• ⅱ) To respond to your requests for information, products, or services;

• ⅲ) To provide you with general health information (such as information on certain health conditions) as well as information about our products and Services;

• ⅳ) To provide you with marketing communications whether about a particular SanReno product or concerning general disease information;

• ⅴ) To determine if you are eligible for certain products, services, or programs (such as patient assistance programs);

• ⅵ) To manage or develop our business relationship with you (e.g., to respond to questions, invite you to events, comply with regulatory obligations, or determine eligibility for SanReno programs);

• ⅶ) To recruit and/or consider you for employment;

• ⅷ) For our research, development, and collaboration efforts;

• ⅸ) For regulatory reporting, such as adverse event or pharmaceutical transparency reporting; and

• ⅹ) For other everyday business purposes, such as payment processing and financial account management, product development, contract management, Site administration, fulfillment, analytics, fraud prevention, corporate governance, reporting, and legal compliance.

• 7. Disclosure of Your Information

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below： 

• 7.1 Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below. 

• ⅰ) Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.

• ⅱ) Business and Research Partners. We may share your personal information with business and research partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.  For example, we may share your information with a research partner regarding our ongoing clinical trials.

• ⅲ) Regulatory Authorities. If you contact us regarding your experience using our products, we may use the information you provide to us to submit reports to the competent government authority, and as otherwise required of us by law.

• ⅳ) Affiliates. We may share your personal information with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide, such as assistance with one of our clinical trials. 

• ⅴ) Software and Interface. We may use third-party software and interfaces as part of the functionality of our Services. Your information may be shared therefore.

• 7.2 Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity. In addition, we may disclose information to our external auditors, attorneys, accountants, and similar professionals based on our legitimate interest in the operation of our business and our obligations to comply with applicable laws and regulations.

• 7.3 Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

• 7.4 Disclosure In the Aggregate/De-identified

• 8. SanReno may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose non-personal information

Non-Personal Information is information that is not personal, such as questions, comments, ideas and suggestions that you provide, or information that we may collect that is not linked to any Personal Information. Non-Personal Information will be treated as non-confidential, and we may disclose and/or use that information without any obligation whatsoever to you, for any purpose and through any means.

• 9. Your Rights

In accordance with applicable law, you may have the right to:

• ⅰ) Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; 

• ⅱ) Request Correction of your personal information where it is inaccurate, incomplete or outdated;

• ⅲ) Request Deletion, anonymization or blocking of your personal information when processing is not based on your consent or when processing is unnecessary, excessive or noncompliant; 

• ⅳ) Request Restriction of or Object to our processing of your personal information when processing is noncompliant;

• ⅴ) Withdraw your Consent to our processing of your personal information. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;

• ⅵ) Be informed about third parties with which your personal information has been shared; and

• ⅶ) If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

• 10. Disclaimer

SanReno or its Affiliates, or their respective employees, officers and agents shall not be liable for any disclosure under the following circumstances:

• ⅰ) any disclosure of your personal information as required by law or relevant governmental authority;

• ⅱ) any disclosure of your personal information caused by your own voluntary or negligent acts;

• ⅲ) any disclosure of your personal information resulting from hackers, computer viruses or temporary closure of SanReno homepage; or

• ⅳ) any disclosure of your personal information resulting from force majeure beyond SanReno’s control.

You acknowledge and understand that, although we have taken reasonable measures, schemes and devises according to the relevant laws and mandatory technical standards of the People’s Republic of China and GDPR, and have established an Information processing system and a comprehensive Information management system, and necessary traceability system, and continuously undertake information management responsibilities, we may not guarantee the avoidance all the leaks, losses, falsifications, improper uses or other information security/privacy violation events caused by a third party or other reasons. Unless it is otherwise compulsorily required by laws, you agree that if the aforesaid events are not caused due to our intentional breach or material negligence, SanReno shall therefore bear no liability for any damage compensations or breach of the contract.

• 11. Global Access

The Website and Services are owned and operated by SanReno in the People’s Republic of China. However, your personal information may be accessible or transferred to our affiliates, vendors, and suppliers who are located in other countries. If you are visiting this site from a country other than the People’s Republic of China, your communication with us will necessarily result in the transfer of information across international borders. Therefore, by using the Sites, you hereby expressly consent to the transfer of your personal information outside your country or region.

 

• 12. Children’s Privacy

The Site is not directed to individuals under the age of thirteen (13), and we do not knowingly collect personal data from children under the age of 13.

 

• 13. Information for California Residents

In case the user of our Service is a California Residents, the following content shall prevail the context.

• 13.1 California Job Applicants

This notice informs you of the personal information we collect and how we use such information as part of our employment application process, pursuant to the California Consumer Privacy Act of 2018.

In connection with your creating a profile and submitting your application, SanReno will collect the following categories of personal information:

• ⅰ) direct identifiers, such as your name and contact information;

• ⅱ) professional information, such as your previous employment and education background; and

• ⅲ) other information you include in your resume and cover letter.

We also may collect information from your social media profile if you create a profile using a social media account, as well as any other personal information you voluntarily provide to us in connection with the application process.

If you accept an offer of employment and subject to your authorization, we will conduct a background check which may include access to additional employment and educational background information as well as criminal record information.

We use the information you provide to evaluate your candidacy for the job opening(s) you apply to and other job openings at SanReno that we think may interest you, to conduct background and reference checks and to communicate with you about such matters. SanReno will generally delete personal information of unsuccessful candidates, but may retain personal information in certain cases, i.e., for consideration for future positions or as necessary to defend against potential legal claims.

We may update this Policy at any time to reflect changes to the personal information we collect and how we use it. If you have questions about this notice, please contact us through the information provided in the “Contact Us” section.

• 13.2 California Consultants and Contractors

In accordance with the California Consumer Privacy Act of 2018, this California Privacy Section for Consultants and Contractors (“Notice”) describes the categories of personal information that SanReno collects about you in the context of your relationship with SanReno and the purposes for which we collect your personal information. In certain circumstances, vendors such as placement agencies may collect this information on our behalf.

We collect the following categories of personal information about you in the context of your relationship with us:

• ⅰ) Direct identifiers: We collect information that directly identifies you, such as your name, address, phone numbers, photograph, government-issued IDs (such as your social security numbers or passport information).

• ⅱ) Professional or employment-related information: We may collect your professional and employment-related information, including your work experience and education and reference information.

• ⅲ) Financial information: We may collect your financial information, such as your bank account and W9 information.

• ⅳ) Information about your use of the internet, our networks, and our devices: We collect information about your use of SanReno email accounts, the internet, and our computers, phones, and other devices to which you have access. We may also collect your information through security cameras if they exist in your workplace.

In addition to the categories listed above, we will collect any other personal information you voluntarily provide to us in the context of your relationship with SanReno.

We use the personal information we collect about you to manage our relationship with you. Uses include:

• ⅰ) Onboarding and access to our administrative and IT systems;

• ⅱ) Payment administration;

• ⅲ) Monitoring the use of IT and other equipment and property for security purposes, to protect against fraud, and to ensure compliance with applicable policies and procedures;

• ⅳ) Complying with our legal obligations under federal and state laws; and

• ⅴ) Our own internal business purposes, including performing analytics and applying algorithms to discover ways to improve our business, identify trends in our workforce, and enhance our service offerings.

 

• 14. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:
SanReno Therapeutics (Shanghai) Limited
info@sanreno.com

 

• 15. Language

This Privacy Policy is written in both English and Chinese, in case of discrepancy, the English version shall prevail.

 

UK Study Subjects Privacy Notice

 

UK Clinicians Privacy Notice