Last updated: 8 May 2018
For the purposes of this Policy, CMC ICOS Biologics, Inc., dba AGC Biologics (“AGC Biologics US”) with registered office at 22021 20th Ave SE, Bothell, Washington 98021 acts as the data controller for the Personal Data that is collected via the Website. As a data controller, AGC Biologics US is responsible for ensuring that the processing of Personal Data complies with applicable data protection law, and specifically with the General Data Protection Regulation.
Please take the time to read this Policy carefully. If you have any questions or comments, please contact us via firstname.lastname@example.org.
By using our Website, you consent to the collection and use of information as set forth in this Policy. In the event that AGC Biologics would like to use a user's Personal Data (as defined above) in a manner beyond those set forth in this Policy, AGC Biologics will provide you with notice and the opportunity to "opt-out" of such purposes by sending an email to email@example.com.
2. What Personal Data does AGC Biologics collect and why?
When a user completes an AGC Biologics contact form on the Website, the user will be required to provide certain Personal Data, including first and last name, email address, and phone number. AGC Biologics may take this information and integrate it with other information submitted by the user, or other information in the possession of AGC Biologics, in order to provide a quality user experience.
|Why We Collect It||Types of Personal Data||Legal Basis|
Providing you information about our products or services, contacting you, upon your request
Name, email address and phone number by completing a contact form
|On the basis of your consent;
Legitimate interest of AGC Biologics: AGC Biologics’ business management such as contacting you via email or phone about our services
We may also collect certain information automatically from your device. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Tracking Cookies” below.
3. Use of Personal Data
Personal Data collected through this Website is utilized by AGC Biologics only as set forth in this Policy and in order to fulfill your requests for products and services, to contact you, to conduct research, and to provide services to users. AGC Biologics may also use Personal Data submitted to send you information on products and promotions.
AGC Biologics will only share a user's Personal Data under certain scenarios, as follows:
• Within AGC Biologics for purposes consistent with this Policy. We take precautions to allow access to Personal Data only to those staff members who have a legitimate business need for access and with a contractual prohibition of using the Personal Data for any other purpose.
• To our third party vendors, services providers and partners who provide data processing services to us, or who otherwise process Personal Data for purposes that are described in this Policy or notified to you when we collect your Personal Data. This may include disclosures to third party vendors and other service providers we use in connection with the services they provide to us, including to support us in areas such as IT platform management or support services, infrastructure and application services, marketing, and data analytics.
• To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
• To our auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the Personal Data for any other purpose.
• To a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Policy.
• To any other person with your prior consent to the disclosure.
4. How we protect your privacy
AGC Biologics takes all reasonable measures to protect your Personal Data. To ensure the security and confidentiality of the Personal Data we collect on our Website, we use data networks protected by industry standard firewall and passwords. We take measures designed to protect collected Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction.
AGC Biologics does not sell, rent or trade any of your Personal Data to third parties without your consent. Personal Data is not transferred to third parties unless provided for otherwise in this Policy. AGC Biologics may store information with a third party in encrypted form on secure servers.
AGC Biologics will process Personal Data in accordance with this Policy, as follows:
• Fairness: We will process Personal Data fairly. This means that we are transparent about how we process Personal Data and that we will process it in accordance with applicable law.
• Purpose Limitation: We will process Personal Data for specified and lawful purposes, and will not process it in a manner that is incompatible with those purposes.
• Proportionality: We will process Personal Data in a way that is proportionate to the purposes which the processing is intended to achieve.
• Data Accuracy: We take appropriate measures to ensure that the Personal Data that we hold is accurate, complete and, where necessary, kept up to date. However, it is also your responsibility to ensure that your Personal Data is kept as accurate, complete and current as possible by informing us of any changes or errors.
• Data Security: We use appropriate technical and organizational measures to protect the Personal Data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.
• Data Processors: We may engage third parties to process Personal Data for and on behalf of AGC Biologics. We require such data processors to process Personal Data and act strictly on our instructions and to take steps to ensure that Personal Data remains protected.
• International Data Transfers: Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Specifically, our servers are located in the United States, and our group companies and third party service providers and partners operate in the US, Denmark, Germany and Japan. This means that when we collect your Personal Data, we may process it in any of these countries.
However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Policy. These include implementing an intra-group data transfer agreement (“Intra-Group Data Transfer Umbrella Agreement”) based on the European Commissions’ Standard Contractual Clauses for transfers of Personal Data between our group companies, which require all group companies to protect Personal Data they process from the European Economic Area or EEA, in accordance with European Union data protection law.
Our Intra-Group Data Transfer Umbrella Agreement can be provided on request. We have implemented similar appropriate safeguards with our third party services providers and partners.
• Data Retention: We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
5. Personal data and children
Without a parent's or guardian's consent, no Personal Data should be submitted to our Website by children. AGC Biologics will not knowingly collect or use Personal Information from children.
6. Your data protection rights
You have the right to obtain information on all of your stored Personal Data: to receive, to review, and if necessary, correct or erase your Personal Data. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
• If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us at firstname.lastname@example.org.
• In addition, in certain circumstances, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data, or request portability of your Personal Data. Again, you can contact us at email@example.com.
• If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us at firstname.lastname@example.org.
• If you have a complaint or concern about how we are processing your Personal Data, we will endeavor to address such concern(s). If you feel we have not sufficiently addressed your complaint or concern, you have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
7. Links to other Websites
The AGC Biologics Website may contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies and we urge you to review them. They will govern the use of Personal Data you submit whilst visiting these websites.
We do not accept any responsibility or liability for the privacy practices of such third party websites, and your use of such websites is at your own risk.
8. Tracking Cookies
Upon a user accessing the Website, AGC Biologics will check for the presence of an existing tracking cookie. If one does not exist, AGC Biologics or a third party will generate at least one cookie (a small data file) for the individual user. This cookie allows AGC Biologics or the third party to identify the user's computer and Internet browsing software as a unique visitor. These cookies allow AGC Biologics and the third parties it uses to provide a more personalized experience for the user. While the default for most Internet browsers is to accept cookies, you may choose to change these settings in order to notify you when a cookie is being sent, or to refuse transmission/receipt of all cookies. If you would like more information about this practice and your choices about not having this information used by third parties, please contact us at email@example.com.
9. Google Analytics – Statement
10. Updates to this Policy
AGC Biologics may update this Policy from time to time in response to changing legal, technical or business developments. When we update our Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Policy changes if and where this is required by applicable data protection laws.
You can see when this Policy was last updated by checking the “last updated” date displayed at the top of the Policy.
If you have any additional questions or concerns about this Policy, please feel free to contact us any time at firstname.lastname@example.org.