Global Privacy Notice
Thank you for choosing to be part of our community at S-Alpha Therapeutics, Inc ("Company," "we," "us," or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at [salpha@salphadtx.com].
This privacy notice describes how we might use your information if you:
Visit our website at https://www.salphadtx.com/
Engage with us in other related ways ― including any inquiry, request, or discussion relating to partnership, recruitment, clinical trials, or our business in general.
In this privacy notice, if we refer to:
"Website," we are referring to any website of ours that references or links to this policy
"Services," we are referring to our Website, and the services provided therein (e.g., “Become a Partner”, “Join Our Team”, “Contact Us”, and other services we may provide from time to time via our Website), including any inquiry, request, or discussion relating to partnership, recruitment, or our business in general.
The purpose of this privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect.
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. HOW DO WE PROTECT YOUR INFORMATION
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you (i) fill-in the form in our Website prepared for the purpose of rendering one or more of our Services (e.g., “Become a Partner”); (ii) contact us via email, or via other means of communication, regarding partnership, recruitment, or general inquiry; or (iii) participate in activities on the Website (e.g., downloading press release materials from our Website).
The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:
Personal Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; organizations; job titles; medical specialty; doctor’s license number; clinical trial experiences, completion of mandatory training under applicable clinical trial regulations, contact preferences; inquiries; partnership requests; resume and portfolio; and other similar information.
In addition to the above, we collect information that you provide (e.g., information on your business card) at our offline events.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.
We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (e.g., your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website (access logs) and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity on the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
Performance of a contract or to take steps prior to entering into a contract
To take steps at the request of the user prior to entering into a contract of partnership, employment, clinical trials, etc., as construed in the inquiry, request, or discussion and delivered to us via Services.
To evaluate the inquiry, request, or discussion relating to partnership, recruitment, clinical trials, or our business in general, prior to entering into the contract pertained therein.
To enforce our terms, conditions and policies for business purposes in connection with our contract.
To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
To respond to user inquiries. We may use your information to respond to your inquiries and solve any potential issues you might have with our Website or business in general.
To request feedback. We may use your information to request feedback and to contact you about our Website and business in general.
To improve our Services and to provide new services.
Use of information based on legitimate interests of us and/or third parties
To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below).
To deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
Where we rely on our legitimate interests, we conduct a balancing test to document our interests, to consider what the impact of the processing will be on the relevant individuals and to determine whether the individuals’ interests would outweigh our interests if the processing were to take place. You can obtain more information about this balancing test by using the contact details at the end of this privacy notice.
Use of information based on your consent
To process the user’s inquiry, request, or discussion, delivered to us via Services, in accordance with its specific purpose (e.g., general inquiry, partnership request, job application, etc.)
To send you the invitation for future clinical research projects.
To place cookies. We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information.
On other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time. When we rely on consent, and you will have the right to withdraw your consent at any time. To exercise this right, please see the WHAT ARE YOUR PRIVACY RIGHTS? Section below.
Change of purpose
We will use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
For purposes which are required by law
To comply with legal and regulatory requirements.
To respond to requests from judicial, law or regulatory enforcement authorities and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Business Partners. We may share or transfer your information with service providers to render Services to you. For example, we may work with the service providers for web hosting/data storage and infrastructure for efficient storage and processing of your data. Such business partners directly control and manage your personal information.
Business Advisors. We may share or transfer your information with our lawyers, accountants, business consultants, insurers, auditors, to the extent necessary for them to provide with their services.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in South Korea. If you are accessing our Website from outside South Korea, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in South Korea and US.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses can be provided upon request.
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
In principle, we immediately destroy relevant personal information after the purpose of collection and use is achieved. However, if applicable laws and regulations require us to retain the data, we will store it for such period of time prescribed in the applicable laws and regulations. In such case, we will transfer the relevant data to a separate database or other storage place.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We do not knowingly collect data from or market to children under 16 years of age unless a child participates in a clinical trial with the legitimate consent under the applicable clinical trial laws.
We do not knowingly solicit data from or market to children under 16 years of age. By using the Website, you represent that you are at least 16 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 16, please contact us at [salpha@salphadtx.com].
Some of our clinical trials involve participants that are children. We only process a child’s personal information with parental consent or the consent of a legal representative and in accordance with the laws where the clinical trial is being conducted.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information (in particular, where we do not have to process the data to meet a contractual or other legal requirement).
To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. These rights may be limited, for example, if fulfilling your request would reveal personal information about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in the GDPR and in equivalent national laws. We will inform you of the relevant exemptions that we rely upon, if relevant, when responding to your requests.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
8. WHAT ARE YOUR PRIVACY RIGHTS?
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
In Short: We have put in place appropriate physical and technical measures to protect your information.
We take protection of your information seriously and have put in place appropriate physical and technical measures to safeguard the information we collect in connection with the Services. Our security measures are state of the art. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.
10. HOW DO WE PROTECT YOUR INFORMATION
B. Collected personal information from the following categories of sources:
- From a user or user’s devices, for example, through a user’s use of the Services.
C. Collected personal information for the following business or commercial purposes (in addition to the purposes listed above in our Privacy Notice :
- Operating services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing similar services;
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- Debugging to identify and repair errors that impair existing intended functionality;
- Undertaking internal research for technological development and demonstration; and
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Company.
D. Disclosed the following categories of personal information for a business purpose:
- Identifiers such as a real name, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology that can identify a user; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, and other similar identifiers;
- Commercial information, including records of services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
- Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements; and
- Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics and aptitudes.
E. Disclosed personal information for a business purpose to the following categories of the third parties:
- The Company’s business partners;
- Vendors who provide services on its behalf, including clinical research services, database management, or web hosting services;
- Professional services organizations, such as auditors and law firms;
- A third party as part of an actual or planned merger or transfer, acquisition or sale, or in the event of a bankruptcy;
- Other third parties when you separately consent to or request such sharing; and
- Government entities, including law enforcement.
Californian Residents’ Privacy Rights
As a resident of the state of California, you may request, twice in a 12-month period, the following information about the personal information we have collected about the user for the past 12 months:
- Categories and specific items of personal information we collected about the user;
- Categories of sources from which we collected the personal information;
- Business or commercial purpose for which we collected or sold the personal information;
- Categories of third parties with whom we shared the personal information; and
- Categories of personal information about the user that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
You may have the right to request us to provide with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of each of such third parties. In addition, you have the right to request us to delete the personal information the Company has collected from the user.
We will not deny, charge different prices for, or provide a different level or quality of goods or services if a user chooses to exercise these rights. To submit an access or deletion request, click here or contact us as specified in the HOW CAN YOU CONTACT US ABOUT THIS NOTICE?Section of this Privacy Notice. To help protect your privacy and maintain security, we take steps to verify user’s identity before granting any access to your personal information or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. DO WE MAKE UPDATES TO THIS NOTICE?
If you have questions or comments about this notice, you may email us at [salpha@salphadtx.com] or by post to:
S-Alpha Therapeutics
2nd F., 311 Gangnam-daero, Seocho-gu, Seoul, Republic of Korea
A user may report all complaints related to the protection of personal information arising in the course of using our service to the Privacy Officer or the responsible department. We will promptly provide sufficient response to users’ reports.
· Name:
· (Tel), (email), (Fax)
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit : https://www.salphadtx.com/contact
<Addendum>
This Privacy Notice shall take effect from May 4th 2023
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information as shown in the CCPA Privacy Notice below.
CCPA Privacy Notice
This section supplements our Privacy Notice and applies solely to residents of the state of California. For any user who is protected by the California Consumer Privacy Act (the “CCPA“), the below section will apply. In case there is any conflict between the above general terms of our Privacy Notice and this section, this section will prevail for users who are protected by the CCPA.
During the 12-month period prior to the effective date of this Privacy Notice, we may have:
A. Collected the following categories of personal information:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, doctor’s license number, IP address, email address and account name (ID) | YES |
| B. Personal information categories listed in the California Customer Records statute | Name, contact information | YES |
| C. Protected classification characteristics under California or federal law | Gender and date of birth | NO |
| D. Commercial information | Transaction information, purchase history, financial details and payment information | YES |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements | YES |
| G. Geolocation data | Device location | NO |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | YES |
| I. Professional or employment-related information | Business contact details in order to provide you our services at a business level; medical specialty, clinical trial experiences, completion of mandatory training under applicable clinical trial regulations | YES |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | YES |