Axovia Therapeutics, Inc. (“we”, “us”, “our”) respect your privacy. This Privacy Notice explains our practices with respect to personal data we collect and process in connection with your relationship with us. This includes information we collect through, or in association with, our website, together with all products and services we may offer from time to time via our website, or otherwise through your interactions with us (the website, products, services, collectively, the “Services”).
Please review the following to understand how we process personal data about you. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.
2. What Personal Data Do We Collect?
We collect personal data from and about you through the Services, including:
- When you provide it to us directly;
- Automatically through logging and analytics tools, cookies, pixel tags, and as a result of your use of and access to the Services; and
- From third-party sources, including service providers such as Google Analytics.
Finally, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.
Information You Share With Us. We collect personal data from you when you provide it to us, including through website forms, applying for a job with us, or contacting us with questions or comments.
For example, if you contact us for information or with questions, you must provide us with your contact information.
To apply for a job with us, you may be asked to submit your contact information and your resume through a form on the website. This information will form the job application that you submit to us in response to a job posting and will be used in our recruitment process once submitted.
Information Collected Automatically. When you browse or use the Services, we utilize commonly-used logging and analytics tools, including Google Analytics, to collect information about your device, the network used to access the Services, and information about your use of the Services (such as how you navigate and move around the Services).
We also use certain technologies on the Services, including cookies and pixel tags, that allow us, our service providers, and other third parties to store information locally on your device, identify your device, track your interactions with messages we send, and track activity over time and across websites.
Information collected automatically includes the software and hardware attributes of the device you use to access the Services, unique device ID information, regional and language settings, performance data about the Services, network provider, and IP address (a number assigned to your device when you use the Internet). In addition, information is collected passively in the form of log files and third-party analytics (including Google Analytics) that record website activity. For example, log file entries and analytics data are generated every time you visit a particular page on our website, and track the dates and times that you use the Services, the pages you visit, the amount of time spent on specific pages, and other similar usage information, and general data (including the name of the web page from which you entered our website).
Information Obtained from Third Parties. We receive personal data from third parties that we have engaged to provide services to us, as well as from third parties that provide web analytics and usage information to us such as Google Analytics.
3. How Do We Process Personal Data?
Operational Uses. We process your personal data as part of our operations, which include:
- Managing your inquiries, responding to inquiries and requests via email, and communicating with you through any newsletters or other updates;
- Operating, maintaining, and improving the quality of the Services and such content, products and/or services as we may make available through the Services;
- Recruiting activities, including assessing your qualifications and/or capability for a particular job, role, or task and processing pre-employment background checks;
- Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies;
- Endeavoring to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties; and
- For other purposes, as permitted or required by law.
Legal Basis for Processing. We process personal data for, or based on, one or more of the following legal bases:
- Performance of a Contract. By using the Services, you have contracted with us through the Terms of Service, and we will process certain personal data to perform under that contract.
- Legitimate Interests. We may process personal data for our legitimate interests, including complying with any applicable law, rule or regulation, investigation or remedy; enforcing our Terms of Service; protecting our, our users’ or others’ rights, property and safety; and detecting and resolving any fraud or security concerns.
- Compliance with Legal Obligations and Protection of Individuals. We may process personal data to comply with our legal obligations, including as required by valid legal process, governmental request, and to protect those individuals who use our Services and others.
- Your Consent (solely in instances where we specifically request it).
- We share personal data with our service providers, including software and Web developers, commercial email providers, security consultants, and other vendors we engage so that they may provide services to us or on our behalf;
- We may share personal data we collect with certain affiliates, partners, prospective partners, and service providers in order to provide us and/or our affiliates and partners with information about the use of the Services and levels of engagement with the Services and to allow us to enter into new business relationships; and
- We share personal data with third parties when we believe it is required by, or necessary to comply with, applicable law.
4. Your Rights Regarding Personal Data
You have certain rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us at email@example.com. Your rights vary depending on the laws that apply to you, but may include:
- The right to know whether, and for what purposes, we process your personal data;
- The right to be informed about the personal data we collect and/or process about you;
- The right to learn the source of personal data about you we process;
- The right to access, modify, and correct personal data about you (see the “Accessing, Modifying, Rectifying, and Correcting Collected Personal Data” section below for more information);
- The right to know with whom we have shared your personal data with, for what purposes, and what personal data has been shared (including whether personal data was disclosed to third parties for their own direct marketing purposes);
- The right to withdraw your consent, where processing of personal data is based on your consent; and
- The right to lodge a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.
Accessing, Modifying, Rectifying, and Correcting Collected Personal Data
We strive to maintain the accuracy of any personal data collected from you, and will try to respond promptly to update our records when you tell us the information in our records is not correct. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and notify us as soon as possible of any updates or corrections by emailing firstname.lastname@example.org.
Depending on the laws that apply to you, you may obtain from us certain personal data in our records. If you wish to access, review, or make any changes to personal data you have provided to us through the Services, please contact us at email@example.com. We reserve the right to deny access as permitted or required by applicable law.
Your California Privacy Rights
California Civil Code Section 1798.83, known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge.
We do not disclose personal data protected under the “Shine the Light” law to third parties for their own direct marketing purposes.
Your European Union and UK Privacy Rights
European Union and UK privacy law provides individuals with enhanced rights in respect of their personal data. These rights may include, depending on the circumstances surrounding the processing of personal data:
- The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you;
- The right to request restriction of processing of personal data or object to processing of personal data carried out pursuant to (i) a legitimate interest (including, but not limited to, processing for direct marketing purposes) or (ii) performance of a task in the public interest;
- In certain circumstances, the right to data portability, which means that you can request that we provide certain personal data we hold about you in a machine-readable format; and
- In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain personal data we process about you.
Note that we may need to request additional information from you to validate your request. To exercise any of the rights above, please email firstname.lastname@example.org.
5. Security of Personal Data
We employ reasonable physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. Those safeguards include: (i) the pseudonymization and encryption of personal data where we deem appropriate; (ii) taking steps to ensure personal data is backed up and remains available in the event of a security incident; and (iii) periodic testing, assessment, and evaluation of the effectiveness of our safeguards. However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.
6. Your Choices
You have the ability to make certain choices about how we communicate with you, and how we process certain personal data.
Cookies, Web Tracking, and Advertising
Please consult our Cookie Notice [Insert hyperlink] for more information about how to change your browser settings to block the automatic collection of certain information. Please note that disabling or removing cookies may prevent the Services, or certain functionality on the Services, from working correctly or at all.
7. Retention of Personal Data
We retain personal data for the time periods permitted or required by applicable law, as well as to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties.
8. Other Important Information About Personal Data and the Services
Collection of Personal Data from Children
Children under 16 years of age are not permitted to use the Services, and we do not knowingly collect information from children under the age of 16. By using the Services, you represent that you are 18 years of age or older, or are 16 years of age or older and have valid parental consent to do so.
Third-Party Websites and Services
As a convenience, we may reference or provide links to third-party websites and services. When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access these third-party services at your own risk. This Privacy Notice does not apply to any third-party services; please refer to the privacy notice or policies for such third-party services for information about how they collect, use, and process personal data.
We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.
Do Not Track
We use analytics systems and providers that process personal data about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.
Note, however, that you may find information about how to opt out of Google Analytics and block or reject certain tracking technologies in our Cookie Notice.
Your personal data will be stored in the United Kingdom and processed in the United States, European Union and the United Kingdom. By your use of the Services, you acknowledge that we will transfer your data to, and store your personal data in, the United Kingdom, which may have different data protection rules than in your country, and personal data may become accessible as permitted by law in the above jurisdictions, including to law enforcement and/or national security authorities in those jurisdictions. For transfers of data into and out of the United Kingdom, we use data transfer agreements subject to approved standard contractual clauses.
9. Modifications and Updates to this Privacy Notice
This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice. Your continued use of the Services following our posting of any revised Privacy Notice will constitute your acknowledgement of the amended Privacy Notice.
10. Applicability of this Privacy Notice
This Privacy Notice is subject to any agreements, including the Terms of Service [insert hyperlink to Terms of Service] that govern your use of the Services. This Privacy Notice applies regardless of the means used to access or provide information through the Services.
This Privacy Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.
11. Additional Information and Assistance
If you have any questions or concerns about this Privacy Notice and/or how we process personal data, please email us at email@example.com or contact us at:
If you are located in the European Union, and you wish to raise a concern regarding our use of your personal data, you have the right to do so with our lead supervisory authority, the Information Commissioner, which can be reached at https://ico.org.uk/concerns/, or your local supervisory authority.
In order to make this Privacy Notice reasonably accessible to users with disabilities, we follow the Web Content Accessibility Guidelines (WCAG 2.1). Users with disabilities may access the Services, and this Privacy Notice, using standing navigation on the website through the aid of additional software, such as screen readers.