Last Updated: May 23, 2022
Your privacy is important to us and so is being transparent about how we collect, use, and share information about you. This Privacy Policy (“Privacy Policy”) is intended to provide information about how we collect, use, and transfer personal information through our publicly accessible websites (any of our websites such as www.connectbiopharm.com), and on which we post a direct link to this Privacy Policy (collectively the “Site”). “Connect,” “we,” and “us” refer to Connect Biopharma Holdings Limited and any of our corporate affiliates.
Scope
This Privacy Policy covers data collected when you interact with Connect, including through the Site. This Privacy Policy does not cover data that we collect through webpages that do not display a direct link to this Privacy Policy. If you click on a link from the Site to open a third-party site, then data collected by the third-party site operator will be governed by the privacy policy of that third-party site operator, not this Privacy Policy.
What Information We Collect About You and How We Collect It
When you access the Site or otherwise interact with us, we receive data that you actively submit as well as data that we track automatically. Each category is described further below.
Actively Submitted Data: When you request information, subscribe to a mailing list or for a service, respond to an online survey, provide us your information at an event or conference, or otherwise actively send us data, we may collect data such as your name, e-mail address(es), mailing address(es), and telephone number(s). You can opt out of providing information by not entering it when asked and, if such information is required to allow us to respond to your inquiry, then you will receive a notice advising you of this.
Passively Tracked Data: When you visit the Site, we may passively track information on your computer and Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access the Site, the Internet address of websites from which you link to our Site, the computer technology you are using, and your movements and preferences on our Site. We use technology that many other websites employ, such as “cookies” or small data files stored on your computer’s hard drive, to collect such information. In some instances, we may use cookies to collect information in connection with future visits from that website, to recognize you as a previous visitor, or to track your activities on our Site. If you follow a link to the Site from a third-party site or promotion, then we store information about your arrival from that third party site or promotion in a session cookie. You do not need to have cookies turned on to visit our Site. You can refuse cookies by turning them off on your browser. Please read our Cookie Policy at www.connectbiopharm.com/cookie-policy/ for additional information.
Combinations: To the extent permitted by applicable law, we may combine passively tracked data with personal data that you actively submit.
Why We Collect Information and How We Use It
We collect passively tracked data primarily to administer, protect, and improve our Site and our systems, to better understand the preferences of our Site visitors, to identify server problems, to compile aggregated statistics about Site usage, and to help personalize your experience on our Site. We do not deliver third party online advertisements on our Site but we may advertise our products and services on others’ websites. We also may work with service providers to deliver retargeting advertisements and other advertisements on our behalf to Site visitors.
We collect actively submitted data primarily for two purposes: First, for the purpose for which you originally sent us the data (e.g., to provide information to you); and second, for purposes of contacting you to further discuss your interest in our company or our product. You can opt out of receiving marketing emails as explained below. We may also perform analytics on this data to understand how our Site is used.
When and How We Share Information with Others
We may share your information with Connect corporate affiliates. We engage agents and service providers who process data only on our behalf and for our purposes under written agreements that include confidentiality requirements. We may share your information as required by law or in the interest of protecting or exercising our or others’ legal rights, such as in connection with requests from law enforcement officials and in connection with court proceedings. We may share or transfer your information in connection with a prospective or actual sale, merger, transfer, or other reorganization of all or parts of our business. We reserve the right to fully use and disclose any information that is not in personally identifiable form (such as statistics and survey results that do not identify you individually by name). We do not sell your personal information.
International Data Transfers
Your personal information may be transferred to countries located outside your country or region, including to countries or regions that may not provide a similar or adequate level of protection to that provided by your country or region. For example, if you reside in the European Economic Area (“EEA”), then we may transfer your personal information to China, the United States, or other countries outside of the EEA. By using the Site or otherwise providing personal information to us, you hereby expressly consent to the transfer of your personal information outside your country or region. Connect employs approved legal mechanisms to comply with privacy laws when transferring your data outside of the EEA, Switzerland, or the United Kingdom.
Additional Information for Individuals in the European Economic Area (EEA)
In addition to the disclosures made elsewhere in this Privacy Policy with respect to our privacy practices, our legal basis for processing personal data we collect in the EEA can vary depending on the manner in which you use our Site or otherwise engage with us. Our legal basis for processing information about you is with your consent in cases where you authorize us to engage in processing, such as an affirmative request to receive communications from us. If you provide consent, then you can withdraw your consent at any time, although this will not affect the lawfulness of our processing prior to your withdrawal of consent.
In the case of processing involving passive data collection and other processing for the administration of our Site, such processing is undertaken pursuant to our legitimate interests as a data controller, including the operation of our Site. We also may process personal data where necessary for our compliance with a legal obligation to which we are subject. We also reserve the right to process personal data in the event we believe doing so is necessary to protect the rights of the data subject or another person.
More specific information about the basis for our processing may be included on specific notices or forms and, in the event of a conflict, the purposes identified on a specific form will take precedence over the purposes identified here.
If you have concerns about our processing of your personal data, then you may contact our privacy point of contact, using the contact information below. You also have the right to file a complaint with your country’s data protection supervisory authority.
How You Can Opt-Out
In connection with certain matters, we may ask you specifically whether you have objections against a certain kind of data use or sharing. If you opt-out under such circumstances, then we will respect your decision. To opt out of receiving commercial communications from Connect, please click on the “opt-out” link in the communication or contact us at optout@connectpharm.com. Please note that our partners and other data recipients have their own data privacy policies, which may differ from ours and you would have to contact them separately with respect to opt-out requests.
How You Can Access and Update Information We Collected About You
As required by applicable law, upon request we will provide you with information about whether we hold any personal information about you. You may request this information by emailing us at privacy@connectpharm.com.
If personal information we hold about you is no longer accurate, current, or complete, and you wish to update it, then please send an e-mail to privacy@connectpharm.com. Upon appropriate request, we will update or amend personal information about you, but we reserve the right to use previously obtained information to verify your identity or take other actions that we believe are appropriate or permitted by law.
Note that we do not distribute your personal information to third-parties for third-party direct marketing purposes.
How We Protect Information
To help protect the privacy of your personal information collected through the Site, we maintain physical, technical, and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to personal data to those persons who need to know that information to operate our business. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of personal information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
How Long is Personal Information Retained
We will keep your personal information only as long as is reasonably necessary for the purposes described in this Privacy Policy or longer as may be required by applicable law.
Minors
This Site is not directed towards children under 13 years of age nor do we knowingly collect information from children under 13 years of age. If you are under 13 years old, then please do not use the Site or submit any personal information to us. If you believe that we have unintentionally collected personal information about your child, then you can contact us by mail or email as described below.
Effective Date and Changes to this Privacy Policy
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may revise this Privacy Policy from time to time. Any changes will be effective when we post the revised Privacy Policy. If the Privacy Policy changes in a way that significantly affects how we handle personal data, we will not use the personal data we previously gathered in a manner described in the new policy without providing notice, such as through a banner or email, and/or obtaining your consent, as appropriate and/or required by law. We recommend that users revisit this Privacy Policy to learn of any changes.
Questions or Concerns
If you have any questions related to this Privacy Policy, please email us at privacy@connectpharm.com and put “Privacy Policy Inquiry” into the subject line of your email.