Privacy Policy
This Privacy Policy applies to your access and use of the Neurimmune Subone AG (“Neurimmune”, or “we”, “us” or “our”) website (“Website”). By using the Website, you confirm that you have read and agree to be bound by this Privacy Policy. If you disagree with any part of his Privacy Policy, please do not use the Website.
This Privacy Policy explains the policies and practices that we have developed to safeguard personal information and to comply with applicable data protection laws.
We control and operate the Website from Switzerland. Our online privacy practices may differ from privacy laws or practices in your state or home country.
We may change our Privacy Policy, so please check this page periodically, as your continued use of the Website, after we publish our changes, indicates your acceptance of any changed terms.
Information We Collect
We provide the Website to share information about the company, its capabilities and its development efforts. Regardless of the device you use to interact with our Websites, Neurimmune may collect some information that identifies you or that can be used to contact or distinguish you as an individual (“Personal Information”), in particular if you contact us via email. We may need to collect Personal Information about you to provide you with information you request, or to facilitate commercial engagements with you.
We will only collect Personal Information about you that is necessary for one or more of our legitimate business purposes, or is required by law.
When you visit our Websites, we use a variety of common, automated data collection technologies, such as internet tags or cookies (“Data Collection Technologies”), to assess how our Websites are used, to personalize your experience, and to deliver content tailored to your interests. In doing this, we collect information about you when you visit our Websites. When you request pages on our Website, for example, our servers automatically log your internet protocol (IP) address. The IP address is a unique number assigned to your computer to identify it whenever you are surfing the Web. We use the IP address to understand the web pages you visit. The IP address does not identify you personally, but it allows us to maintain communications with you as you move about the Website. Generally, these types of data elements (“Other Information”) do not reveal your identity or do not relate directly to you or any other individual.
The following are some examples of Other Information:
- device ID, including IP address;
- browser and device information, including operating system;
- aggregated information such as “click stream” information such as entry and exit points for the Websites (including referring URLs or domains), - certain Websites traffic statistics, page views, and impressions;
- geolocation (if using a mobile application and you consent to providing it); and
- other information collected through cookies, pixel tags and other technologies described in more detail later in this Privacy Policy.
How We Use your Personal Information
If you contact us via email, we will typically have your email address. It would also be common for us to have your name, and perhaps other information, such as your address, phone number, and employment status. This information would be provided to us only to the extent it is included in an email you send to us.
By providing your Personal Information, you agree that, where it is permitted by local law, we may use your Personal Information:
- to communicate with you, including by mail, telephone, facsimile, e-mail, mobile alerts and SMS text messaging;
- to notify you of our new business opportunities and to provide you with product news and updates, promotional materials or newsletters, tips, or other helpful information;
- to seek your views on our efforts;
- to monitor our regulatory compliance;
- to respond to your requests;
- to improve the content or personalize our communications;
- to create a profile about you to match you collaboration opportunities or obtain services from you;
- to consider your application for employment;
- for our own administrative and quality assurance purposes, such as to perform data analysis to identify usage trends, determine the effectiveness of our promotional campaigns and general operation of the Website;
- to improve our level of service; and
- for other purposes that may be detailed on this Website.
When we collect your Personal Information, we will take reasonable steps to advise you of what Personal Information we are collecting, the purposes for which we are collecting the Personal Information and will use such Personal Information only for stated primary or related secondary purposes.
Marketing. We may use your Personal Information for marketing-related activities, including to communicate with you about our products, services, and company and to invite your participation in engagement opportunities (e.g., surveys). You can unsubscribe from marketing communications by clicking the "Unsubscribe" link included in each message.
How We Share Your Personal Information With Others
We may disclose your Personal Information to certain third parties listed below, including third parties who provide us with various business services. We will not sell your Personal Information. We will not otherwise disclose your Personal Information without your consent, except where such disclosure is reasonably necessary for normal business operations and such disclosure is in accordance with all applicable data protection and privacy laws.
a) Affiliates
We may disclose Personal Information to our affiliated companies for the purposes described in this privacy notice. Affiliates are those companies that are under common control of our parent company Neurimmune Holding AG
(b) Third parties/Service Providers
We may disclose your Personal Information to third-party service providers who provide services to us, such as: Website hosting, professional services, including information technology services and related infrastructure, customer service, e-mail delivery, auditing and other similar services. We may also disclose your Personal Information to third parties to respond to a specific request that you make via email. If we allow a third party to have access to your Personal Information, they will only be permitted access for purposes that are consistent with this privacy notice and will be required to protect your Personal Information in accordance with all applicable data protection laws.
(c) Law enforcement
In certain circumstances, we may be called upon to release your Personal Information in response to a court order, subpoena, search warrant, law or regulation. We plan to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the Personal Information that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behavior that is illegal or harmful to individuals or the Personal Information we are responsible for.
(d) Regulators and physicians
If you contact us regarding the use of one of our products, we may use the Personal Information you provide as necessary to submit complaint or adverse event reports to local and international health or pharmaceutical regulators, and as otherwise required by law. We also may use the Personal Information to contact the prescribing physician to follow up regarding an unexpected event involving use of our product.
(e) Corporate transactions
We may disclose your Personal Information to a third party relating to a corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including regarding any bankruptcy or similar proceedings.
(f) Other Legal Reasons
In addition, we may use or disclose your Personal Information as we deem necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (3) to comply with subpoenas and other legal processes; (4) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our affiliates; (6) to protect the rights, privacy, safety or property of Neurimmune, our affiliates, you and others; and (7) to enforce our terms and conditions.
How We Use or Share Other Information
We use Other Information or additional information that we collect for any purpose not prohibited by law. We may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use all Other Information, provided that such information does not personally identify you. If we combine Other Information or additional information with Personal Information in a way that can identify or be used to identify you, we will treat that information as Personal Information.
International Transfers
Neurimmune conducts business or collaborates with other businesses in many countries. Transfers of Personal Information to third parties may include transfers to a country where the laws provide different protection from your country. In such cases, we will take appropriate measures to ensure adequate data protection in accordance with applicable data protection laws.
Your Privacy Choices and Rights
You have the rights and choices regarding Neurimmune’s processing of your Personal Information:
Manage email. You may request email updates about developments at Neurimmune. If you decide, at any later time, that you no longer wish to receive these emails, you may do so by sending an email to privacy@neurimmune.com.
Manage cookies. Most web browsers allow control of cookies through the browser settings. You can set your browser to notify you when you receive a cookie, which will enable you to decide if you want to accept it or not. However, if you do not accept a cookie, certain elements of the Website may not function correctly or completely.
Access/review/update Personal Information. If you become aware that Personal Information we maintain about you is inaccurate, incomplete, misleading, irrelevant or out of date, or if you would like to access, update or review your information, you may contact us at privacy@neurimmune.com. We will attempt to provide the requested information or make requested changes to the extent allowable by applicable privacy or other laws. In any event, we will respond to you as soon as reasonably possible, to advise you of the outcome of your request.
Remove Personal Information. You may request the removal of previously provided Personal Information at any time using privacy@neurimmune.com. Please be aware that we may not comply with your request to amend or remove information that was provided to Neurimmune by a healthcare professional or a consumer regarding an adverse drug event.
Please note that some of the above rights are limited by applicable information protection law and we have the right to collect, process and hold your Personal Information to perform our legal obligations (for example: data regarding an adverse drug event). We may require you to provide additional information necessary to confirm your identity before we comply with any request made by you.
Data Collection Technologies, Interest-Based Advertising and “Do Not Track”
Data Collection Technologies. In addition to collecting your IP address as described above, we may also use certain Data Collection Technologies on our Websites such as:
Cookies. Cookies are small text files placed in your computer browser or other web-accessing device directories to store your information about your use of the Websites and your activities online (collectively, “Cookies”). A Cookie will typically contain the name of the domain (internet location) from which the Cookie has come, the “lifetime” of the Cookie (i.e. when does it expire), and a value, usually a randomly generated unique number. To find out more about Cookies, including how to see what Cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
We use first-party, session, and persistent cookies. These cookies allow us to distinguish you from other users of our Websites, and to enhance this Website and your experience when you browse this Website.
If you do not wish to receive Cookies or wish to manage when you accept Cookies in general, you may set your browser to reject Cookies or to alert you when a Cookie is placed on your computer. Although you are not required to accept our Cookies, if you set your browser to reject Cookies, you may not be able to use all the features and functionality of the Website.
Internet tags. Occasionally, we may use Internet tags (also known as Web beacons, action tags, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by-1 GIFs) on our websites.
Cookies and Internet tags are placed on different pages throughout our Websites. We also use them to measure responses to our Websites. We may deploy Cookies and Internet tags through our analytical service partners.
Social Plugins. The Website may also use social plugins (e.g., the Facebook “Like” button) to enable you to easily share information with others. When you visit our Website, the operator of the social plugin may be able to place a Cookie on your computer, enabling that operator to recognize individuals who have previously visited our Website. For further details about the information shared via a social media plugin, you should refer to that social media website’s privacy statement.
Google Analytics
This Website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses Cookies. The information generated by the Cookie about your use of this Website is generally transferred to a Google server in the United States and stored there. Because we have activated “internet protocol anonymization” on this Website, Google shortens your IP address at a point within the European Economic Area before transfer to the United States. This means that the full IP address will only be transferred to Google in the United States only in exceptional circumstances for shortening there.
Google will use the received information to evaluate your use of this Website for Neurimmune, to compile reports on website activity, and to provide other services related to website usage and internet usage. The IP address provided by your browser as part of Google Analytics will not be merged with any other Google data.
Do not track (DNT). We do not respond to DNT signals offered by some browsers.
OUR SECURITY MEASURES
We have implemented reasonable safeguards designed to prevent loss, misuse and unauthorized access, disclosure or modification of Personal Information provided or collected through the Websites. Unfortunately, no system or online transmission of data can be guaranteed to be 100% secure and you should always take appropriate security measures to protect your Personal Information, including ensuring that you have up-to-date antivirus software.
STORAGE & RETENTION
We provide products and services around the world. Accordingly, we store and process Personal Information on Neurimmune’s servers, and the servers of third parties we hire to provide our services, worldwide. These servers may be located outside the country from which you interacted with Neurimmune.
We retain your Personal Information for no longer than is necessary for the purposes for which it has been collected.
LINKS TO OTHER SITES
Our Websites may feature links to third-party websites that we believe you might find useful and informative. We do not endorse or recommend these websites’ content or services, and we are not responsible for the privacy practices of the operators of these other websites. We encourage you to be aware of and read the privacy notice of each website you visit. When you link these third-party websites, please remember that you are bound by the privacy policy of the third-party. We may also partner with other companies to provide you with content or services on a joint or “co-branded” basis using a co-branded website with both the Neurimmune logo and the logo of the co-branded partner displayed. You should read the individual privacy policies of the co-branded websites, as these policies may differ in some respects from this privacy notice.
CHILDREN’S NOTICE
We recognize the importance of protecting the privacy of children. Our Websites are neither intended for children nor are they designed to attract child users. Our Websites, their content and our services are intended for users over the age of eighteen (18). We do not knowingly collect any personally identifiable information from children under age eighteen (18). When a user discloses Personal Information on the Websites, the user is representing to us that he or she is at least eighteen (18) years of age. If we learn a user under the age of eighteen (18) has volunteered personally identifiable information via an email, we will delete such information from our active databases.
CONTACT US
If you have any concerns about the way your Personal Information has been collected or handled by Neurimmune, or any queries regarding this privacy statement, you can contact Neurimmune at privacy@neurimmune.com.
GENERAL DATA PROTECTION REGULATION (GDPR) – EUROPEAN REPRESENTATIVE
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Neurimmune AG has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:
- by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
- by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
UK GENERAL DATA PROTECTION REGULATIONG (GDPR) - UK REPRESENTATIVE
Pursuant to Article 27 of the UK GDPR, Neurimmune AG has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:
- by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
- by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom