CENTESSA PHARMACEUTICALS PLC
GLOBAL WEBSITE PRIVACY NOTICE
Updated: May 2023
This website is owned and operated by Centessa Pharmaceuticals plc (“Company“, “we“, “us” or “our“) and its group of companies (“Centessa Group“).
We act as the data controller of the personal data collected and processed regarding visitors to these websites.
For any questions in respect of this Privacy Notice, you can contact us at firstname.lastname@example.org
This Privacy Notice explains how we will collect, use, store and transfer personal data from website users.
We process all personal data in compliance with relevant data protection laws, including the GDPR and any applicable privacy laws within the jurisdictions in which we operate, which means that your personal data will be:
- Used lawfully, fairly and in a transparent way
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- Accurate and kept up-to-date
- Retained only for as long as necessary for the purposes we have told you about or when we have a legal obligation to retain for a specific period of time
- Kept securely
- Information We Collect and Use
Personal data is information which identifies you personally or by which your identity can be ascertained. This may include your name, address, e-mail address, and other contact details.
Website & Technical Data
When you visit our websites, we collect standard internet log information and details of visitor behaviour patterns which allow us to better understand how users interact with the website and enable us to improve it, where necessary.
If you do not wish for your data to be used in this way, you may select “decline” in the website cookie banner pop-up.
When you submit your personal details via the “Contact Us” form, we will use that information to respond to your message, which will be relayed to the relevant department, which will respond directly to you.
The information captured via “Contact Us” may be used to manage future communications with you, which may include information about our products and services. We believe that processing data in this way supports our legitimate interests; however, if you do not wish to hear from us, you may unsubscribe at any time by either using the unsubscribe option within the message/email or by contacting us directly at email@example.com
- How We Use Your Personal Data
We process your personal data for the following purposes:
- Undertaking business development, growth, and other operational activities, which are within our legitimate interests
- To respond to queries and requests submitted via the website “Contact Us” form or via email or telephone
- To negotiate, enter into, manage, monitor, and conclude new and existing contracts
- To comply with health and safety requirements
- To comply with our legal and regulatory obligations
Under data protection legislation, including the GDPR, the use of personal data must be justified. Such justification is called a “legal basis” and we apply the following legal bases when processing personal data:
- To fulfil the performance of a contract
- Where we have a legal obligation
- To achieve our legitimate interests, provided this does not affect your rights as a data subject
- To defend, prosecute or make a legal claim
- Where you have been asked to provide your consent
You can see a full list of processing activities and the legal basis on which data are processed in Appendix 1 which can be found at the end of this policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you first and we will explain the lawful basis which allows us to do so.
- Disclosures of Your Personal Data
We may share your personal data with our third-party service providers, agents, subcontractors and other associated organisations, our group companies, and affiliates (as described below) in order to complete tasks. When using third party service providers, they are required to respect the security of your personal data and to treat it in accordance with the law.
We may pass your personal data to the following entities:
- companies and organisations that assist us in providing the websites;
- anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the websites;
- any third party as a result of any restructure, sale or acquisition of our group or any Affiliates, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us; and
- regulatory and law enforcement authorities, whether they are outside or inside of the United Kingdom, where the law allows or requires us to do so.
- International Transfers
Some of our external third parties (described in paragraph 4 above) and certain members of the Centessa Group are based outside the UK and the EU. With that in mind, some processing of your personal data will involve a necessary international transfer of your data.
Where your information is transferred outside the European Economic Area (“EEA“), we will take steps to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this Policy.
· Where we are legally required to do so.
· In order to facilitate the operation of our Group, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
- How We Protect Your Personal Data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, damaged, or accessed in an unauthorised or unlawful way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. Depending on the nature of the risks presented by the proposed processing of your personal data, we will have in place the following appropriate security measures:
- organisational measures (including but not limited to staff training and policy development);
- technical measures (including but not limited to physical protection of data, pseudonymisation and encryption); and
- securing ongoing availability, integrity, and accessibility (including but not limited to ensuring appropriate back-ups of personal data are held).
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. If you want to know more about our security practice, please contact us at firstname.lastname@example.org
- Data Retention
Data protection law does not generally dictate how long any personal data is required to be kept. To determine the appropriate retention period for personal data, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. If you would like more details about retention periods, please contact us at email@example.com
If we determine that we no longer need your personal data to fulfil the purposes we collected it for, we will either erase (delete) it or anonymise it. Here are some typical factors which we usually consider when determining how long we need to retain your personal data:
- in the event of a complaint;
- if we reasonably believe there is a prospect of litigation in respect to our relationship with you or if we consider that we need to keep information to defend possible future legal claims;
- to comply with any applicable legal and/or regulatory requirements with respect to certain types of personal data (e.g., information needed for audit purposes etc); or
- in accordance with relevant industry standards or guidelines.
Please bear in mind that the right to deletion/erasure of your personal data is not absolute which means that in some circumstances, whilst you can ask us to delete your data, we may have lawful grounds to retain it: see Your Rights paragraph below for further information.
- Your Rights
Under certain circumstances, you have rights under the data protection laws in relation to your personal data:
- Right to be informed. This enables you to be informed at all times about who we are and the purposes for processing your personal data. Our Privacy Notices are designed to provide this information.
- Request access to your personal data (commonly known as a ’data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. If a valid erasure request is received, we will take steps to ensure erasure. You will be informed after your personal data has been erased.
- Object to the processing of your personal data. This applies where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your individual rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Right to stop direct marketing. Where we are processing your personal data for direct marketing purposes, you have the right to notify us in writing requesting that we cease or do not begin processing your personal data for direct marketing purposes.
- Rights in relation to automated decision making. This applies if the decision is made solely by automated means (without human involvement). Please be advised that we do not undertake any automated decision-making in relation to data processed via our websites.
- Request restriction/stop of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (1) If you want us to establish the data’s accuracy; (2) Where our use of the data is unlawful but you do not want us to erase it; (3) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; (4) You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format (if feasible). Note that this right only applies to automated information which you initially provided consent for us to use or where you provided the information to us to perform a contract with you.
- Right to withdraw consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You may withdraw consent at any time where we are relying on consent to process your personal data by contacting us through firstname.lastname@example.org However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you wish to exercise any of the rights set out above or if you have any queries regarding how we process your personal data, please contact us at email@example.com
If you are not satisfied with the way that your personal data have been processed, or how we have responded to your queries or requests, you have the right to contact the UK Information Commissioners Office via www.ico.org.uk or any other EU member state Supervisory Authority.
Individuals and data protection supervisory authorities in the EU may also contact our data protection representatives according to Article 27 GDPR:
EU: DP-Dock GmbH, Attn: Centessa Pharma, Ballindamm 39, 20095 Hamburg, Germany
APPENDIX 1 – TABLE OF PROCESSING ACTIVITIES
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your data.
Where we apply the legal basis of legitimate interests, we undertake appropriate risk assessments to ensure that our need and benefit to process your personal data does not outweigh your rights and freedoms or present any possible risks to you.
|PURPOSE / ACTIVITY||LEGAL BASIS FOR PROCESSING|
To manage our relationship with you which can include:
(a) responding to any enquiries or communications from you
(b) asking you to provide feedback or complete a survey
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Sites)
|To administer and protect our business, our website and applications including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data|
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and, where applicable, advertisements or promotions. We may measure or understand the effectiveness of the advertising and promotions we serve.||(a) Necessary for our legitimate interests (to study how customers use our websites, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, marketing, customer relationships and experiences||(a) Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and, where applicable and appropriate, to form our marketing strategy)|
Please contact us via firstname.lastname@example.org if you require details about the specific legal basis we are relying on to process your personal data where more than one base has been set out in the table below.