Effective date: April 2022
Within this Policy you will find covered matters related to the following:
- Information We Collect
- Cookies Policy
- How We Use Your Personal Information and on Which Legal Basis
- Disclosure of Your Personal Information
- Links to Third Party Sites
- Contact Information
- Special Notice to California Residents
- Special Notice about the General Data Protection Regulation (GDPR) in general
- Special Notice to the Participants of Clinical Trials Conducted by Urovant Sciences GmbH (Sponsor) in the European Union specifically
The Services are not directed at children and we do not knowingly collect personal information via the Services from children under the age of 13. If a child provides us with this type of information online, please contact us to have the account deactivated by sending us an e-mail at firstname.lastname@example.org.
Information We Collect
We collect and store information that you provide when using the Services, such as information that you provide during account registration, information you post to Services, and information you provide in response to surveys. For example, this information may include:
- Personal identifiers, including your name, e-mail address, and phone number;
- Professional information and educational information, such as information about your medical speciality;
- Medical information and other health information;
- Demographic information, including your date of birth;
- Geolocation information; and
- Other types of information that you may provide to us via the Services.
We may receive information from commercial sources such as companies that maintain information about healthcare providers and their specialities. We may combine the information we collect from other sources with the information we collect directly from you under this Notice and generate inferences about you.
We use certain cookies that are considered ‘strictly necessary’ for the regular operation and security of our websites, as well as for the provision of the services and products you request. Without these cookies, we will not be able to offer you a secure browsing on our website or provide certain other core features. For these cookies, we do not ask for your consent but we do inform you about their presence on our website.
In addition, other categories of cookies that we use and for which we may be required to ask for your consent are:
- ‘Functional’ cookies that help personalise services by remembering your preferences and settings. For example, they may be used to keep track of what featured products or videos have been viewed so as to avoid repetition. Another function is to measure how users interact with website content, which helps us also to improve our websites and your browsing experience with us. We generally contract with independent measurement and research companies to perform these services for us and, when this is the case, these cookies may be set by a third-party company.
- ‘Advertizing’ cookies that gather information about your activities on our websites and other sites in order to provide you with customised advertizements that are relevant to your interests. Disabling these types of cookies will not opt you out of being served ads. You will continue to receive generic ads.
We may use first-party cookies (cookies set directly by us to your device) as well as cookies served by third parties. Third-party cookies are most commonly used for website analytics or advertizing purposes.
We and our third-party partners may also collect data by using pixel tags, web beacons, clear GIFs or similar means (collectively, pixel tags) that allow us to know when you visit the Services. These are small bits of code, which are imbedded in web pages, ads, and e-mail, that communicate with third parties. We use these to enhance your online experience and understand traffic patterns.
We and our third-party partners also may use other kinds of technologies, such as Local Shared Objects (also referred to as ‘Flash cookies’) and HTML5 local storage in connection with the Services. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings. For HTML5 local storage, the method for disabling HTML5 will vary depending on your browser. For Flash cookies, information about disabling or deleting information contained in Flash cookies can be found here.
For further information about cookies including how to see what cookies have been set on your device and how to manage and delete them, please visit www.allaboutcookies.org.
In Europe, you may also visit www.youronlinechoices.eu to exercise choices about certain cookies.
In the U.S. you may also visit the Network Advertising Initiative’s opt-out page at http://optout.networkadvertising.org/#!/ to learn how to opt-out of third-party, interest-based targeting cookies.
How We Use Your Personal Information and on Which Legal Basis
We may use the data we collect, including your personal information for the following purposes:
- Provide you with products and services, such as to complete registration, fulfil transactions that have been requested, and to manage the Services. We do this on the basis of the performance of a contract we have with you or on the basis of our legitimate interests to be able to provide you with our services
- Improve our products and services, including the Services, and identify, develop, and offer new or expanded products and services. We do this on the basis of our legitimate interests to be able to provide you with relevant offers and to improve our services;
- Personalise your experience with the Services, including customising the content and/or format of the pages of our websites that you visit. We do this on the basis of our legitimate interests to improve your experience and improve our relationship with you, or on the basis of consent received from you;
- Notify you about updates, products, services, and/or special offers that may be relevant to you, both on and off the Services. We do this on the basis of our legitimate interests to improve your experience and improve our relationship with you;
- Ask you to participate in brief surveys. We do this on the basis of our legitimate interests to improve our services;
- To secure, protect, enforce, or defend the legal rights, privacy, safety, or property of Urovant Sciences, the Services, its employees, agents, or other users, or to comply with law. We do this on the basis of our legitimate interests to protect our people, assets and clients, or to comply with a legal obligation; and
- Conduct analysis, generate aggregate data, which is not subject to this Policy, or otherwise conduct research related to our products and services and the use of the Services. We do this on the basis of our legitimate interests to improve our services.
Disclosure of Your Personal Information
We also disclose your personal information to certain third parties with whom we have a direct or indirect business or contract relationship:
- We may share information within our family of affiliated companies.
- We also may share your information with those providing contractual services to us. For example, we may disclose information to third parties that provide administrative or processing services for us, for example, printing, mailing, and/or payment processing, or to those providing hosting services to us.
- We may share your information with business partners to provide the products and services you have requested.
- We will not share end-user personal messaging data with third parties outside of our business partners. Business partners will not use your data for any other purposes other than to provide the products and services you have requested.
We may also disclose your personal information with third parties:
- To secure, protect, enforce or defend the legal rights, privacy, safety, or property of the Urovant Sciences, the Services, its employees, agents, or users.
- To comply with law and in response to legal processes such as subpenas and to cooperate with law enforcement authorities and other governmental authorities consistent with applicable laws, including, for example, to comply with regulatory requirements relating to the safety and efficacy of our products and services.
- In connection with a corporate transaction, such as a merger or acquisition, or in connection with a bankruptcy reorganisation.
- Otherwise with your consent or at your direction, such as when you use interactive features of our Services.
You may opt-out of, or if you are a resident of Switzerland or the EEA, opt-in to receiving certain communications from Urovant Sciences, including text messages, voicemail, or e-mail. In order to opt-out, please follow the unsubscribe instructions in our emails or text messages, or contact email@example.com. Remember, however, that Urovant Sciences may still send e-mail or call you in order to provide a product or service that you request and for other non-commercial purposes, where permitted by law.
Although the Services currently do not have a mechanism to recognise the various web browser Do Not Track signals, we do offer you choices to manage your preferences as described in the sections above. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org
Links to Third-Party Sites
The Services may contain links to other third-party websites and services. Urovant Sciences does not control the privacy policies or practises of these third-party sites. You should review those policies before providing any information. Urovant Sciences is not responsible for the content or practises of any linked third-party sites, and we provide these links solely for the convenience and information of our visitors.
Urovant Sciences has established commercially reasonable safeguards to help prevent unauthorised access to or misuse of your personal information that is stored on our systems. However, no data storage system or transmission of data over the internet or any other public network can be guaranteed to be 100 percent secure. If you use Services that require a password, you should never disclose your password to anyone. Urovant Sciences will never ask you for your password in an unsolicited phone call or e-mail. You are responsible for maintaining the secrecy of your passwords and any account information.
Urovant Sciences reserves the right to change this Policy to respond to new laws, regulations, technology, or for other business reasons. Please cheque this Policy from time to time to review any such changes.
Generally, Urovant Sciences is the controller in relation to the collection and processing of personal information through the Services. If you have any questions or concerns about this Policy, you may contact us by e-mail at firstname.lastname@example.org or write to us in care of: Urovant Sciences, Inc, 5281 California Ave., Suite 100, Irvine, CA 92617.
Special Notice to California Residents
This section supplements the description of our information collection and sharing practises elsewhere in this Policy to provide certain disclosures to California residents whose personal information Urovant Sciences processes pursuant to the California Consumer Privacy Act (‘CCPA’). Please note that these disclosures do not apply to information that is not processed under the CCPA.
- Information We Collect
- How We Use Your Personal Information
- Disclosure of Your Personal Information
We do not treat the ways we share your information as a sale of your information to third parties for money or other valuable consideration, although we do share your information with third parties as discussed in this Policy.
Under the CCPA, California residents may have the right to request that a business that collects consumers’ personal information give consumers additional transparency and access to the specific pieces of personal information that the business has collected about the consumer. California residents also have the right to submit a request for deletion of information under certain circumstances. Please note that these rights are not absolute. For example, we may not delete information we are required to retain for regulatory reasons, certain internal business purposes, or where otherwise provided for by law. As another example, we will not respond to a request if we cannot verify you as the requestor.
Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you for additional information. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
Consistent with California law, if you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law. Please submit your request by sending an email to email@example.com.
California Civil Code Section 1798.83 permits California residents once a year to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident and wish to make such a request, please send an e-mail to firstname.lastname@example.org and include the phrase California Shine the Light Request in the subject line, and provide us with your name, address and e-mail address.
Special Notice about the General Data Protection Regulation (GDPR) in general
The rights you have regarding your personal data. You have certain individual rights regarding the personal data that we collect and process about you through this website. You have the right to access or receive certain information regarding the personal data we process. You also have a right to have your personal data rectified, to object to the processing of your personal data, or to ask us to restrict processing or delete your personal data. You also have a right to data portability and the right to withdraw your consent to a certain processing activity of your personal data. Please note, however, that your rights are subject to exceptions or derogations. Where legally permitted to do so, we may refuse your request to exercise these rights. Specifically, we may need to further process and retain your personal data to comply with contractual obligations relating to you or your company or organisation, to comply with legal obligations or to protect our own legitimate interests. However, you have a right to lodge a complaint with a competent supervisory authority.
How we process and protect your personal data; how long we store it. We collect and process your personal data responsibly and only for the purposes for which it was intended, as set forth in this Privacy Notice and in accordance with applicable laws. We apply adequate technical and organisational security measures, commensurate with the level of known risk, in order to protect the confidentiality and integrity of the personal data we collect on this website. We store your personal data only for as long as necessary for Urovant Sciences to fulfil the purposes for which the data was collected, or when applicable, for as long as Urovant Sciences is legally required to retain the data.
With whom we share your personal data. In connection with the features available on this website, it may be necessary to share your personal data with Urovant Sciences’ group companies and service providers. Specifically, such sharing of data may be necessary in order to respond to your enquiry, to provide access to additional information, or to follow up on your enquiry and inform you about new developments. The data sharing may include transfers to companies or organisations in countries without an adequate standard of data protection. If we transfer personal data collected in the European Union to countries without an adequate standard of data protection, we will do this through the use of standard contractual clauses adopted by the European Commission.
If you have any general questions or concerns about data protection, the Data Protection Officer can be contacted under the following address / e-mail address: Urovant Sciences GmbH Data Protection Officer Viadukststrasse 8 4051 Basel Switzerland email@example.com If you prefer contacting someone within the EU, you can contact or address Urovant's EU Data Protection Representative under the following address: VGS Datenschutzpartner UG Am Kaiserkai 69 20457 Hamburg Germany.
Special Notice to the Participants of Clinical Trials Conducted by Urovant Sciences GmbH (‘Sponsor’) in the European Union specifically
Data protection and security are important to Urovant Sciences. Urovant Sciences is committed to processing your personal data responsibly and in compliance with legal requirements. This section provides further information to participants in the clinical trial RVT-901-3003 and future clinical trials conducted by our affiliate Urovant Sciences GmbH. Please note that this information is provided in addition to and does not replace or contradict information that is contained in the Informed Consent Form that is provided to you as a potential clinical trial patient. In case of conflict between the information in this Notice and the Informed Consent Form, the information in the Informed Consent Form takes precedence.
By participating in a trial conducted by Urovant Sciences as the sponsor, you consent to your health care provider such your hospital, doctor's office, community clinic or university institute (‘Institution’) and its staff (‘Study Team’) collecting and using personal data about you for the study (‘Study Data’). This includes your date of birth/age as permitted by local laws, your sex, your ethnic origin, and personal data on your physical or mental health or condition. The Institution and the Sponsor will use the collected data for the purpose of this study. Both the Institution and the Sponsor are responsible for the handling of the Study Data, in accordance with the legislation on personal data fully applicable in the EU, in particular, the GDPR. Your identity will not be revealed to any person except in case of medical urgency or legal requirement. The treatment, communication, and transfer of the personal data of all the participants will be in accordance with the provisions of this law. The legal basis for processing personal data and processing special categories of personal data (health data) is your explicit consent, to the extent permissible by local rules and where not permissible, other lawful legal basis, and the fact that this data processing is necessary for scientific research purposes. By participating in the Clinical Trial, you consent to the processing of those personal data for purposes specified in this document and for further developing and obtaining regulatory and reimbursement approvals for the study drug. Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, in accordance with EU law (art. 89(1) of the GDPR).
The following information is important with regard to our processing of your personal data: You have the rights to access, correct, delete, and object to or restrict processing of your personal data. You can revoke your consent or object to any further processing of your information. You also have the right to object to any data processing that is necessary for a task carried out in the public interest or that is based on the Sponsor's legitimate interest. However, because the data generated in this study is necessary for scientific and research purposes and is used in a heavily regulated environment, some of your rights mentioned above may be limited. Therefore, we remind you that in the event that you withdraw your consent to any data processing, the data collected up to the point of withdrawal cannot be deleted even if you stop participating in the trial. This is in order to guaranty the validity of the investigation and to comply with the legal duties and with the requirements for the drug authorisation. The data generated in this study is necessary for scientific and research purposes and is used in a heavily regulated environment. In order to exercise your rights, we strongly suggest contacting the Institution. Note that you also have the right to lodge a complaint with the competent supervisory authority if you are not satisfied with the handling of your personal data.
Both the Institution and the Sponsor are responsible respectively for the processing of your data and are committed to comply with the current Data Protection regulations. The data collected for the study will be identified by a code, so that your identity will not be apparent from the data collected about you, and only your Study Team has access to the key that links that data with you and your medical history. Therefore, your identity will not be revealed to any person except to the health authorities if they require it or in cases of medical urgency. Access to your identified personal information will be given to the Bioethics Committee, the representative of the Health Authorities in matter of inspection and personnel or specialised service providers authorised by the Sponsor, to verify your personal data, the fulfilment of the procedures of the clinical trial and the Good Clinical Practise rules (always maintaining the confidentiality of the information) at the study site area. The Institution and the Sponsor are required to keep the data collected from the study at least 25 years after its completion. Subsequently, your personal information will only be kept by the Institution for your health care and by the Sponsor for other scientific research purposes if you have given your consent for it, and if the law and applicable ethical requirements allows it. Adequate, state-of-the-art measures are in place to safeguard your personal data from data loss or other damage to data integrity, theft, or unauthorised access. The Sponsor intends to transfer your personal data to other entities of the Sponsors group as well as to service providers or to investigators outside the EU. For such transfers, your personal data will be protected with safeguards such as contracts or other mechanisms according to art. 45 et seqq. GDPR. Third parties will only process your personal information according to the instructions of the controllers and where they have agreed to treat the information confidentially and to keep it secure.