Privacy Policy
The Reason Behind This Privacy Policy
The Website Privacy Policy (the “Policy”) governs the collection, use and retention by InnoSIGN of personal data relating to your use of the www.innosignbio.com website (the “Website”).
This Policy applies to all Website users.
The Policy consists of five main components and informs you about:
- Who we are and how you can contact us;
- The reason behind this Policy;
- The purposes for which we process your personal data and the related legal basis under the General Data Protection Regulation (GDPR);
- What your rights are in relation to the personal data we hold about you and how you can exercise them; and
- Further details on how we process your personal data.
This Policy may be updated periodically to reflect changes in our personal data processing practices. In that case we will post a notice on the Website to inform you of any significant changes.
THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA AND APPLICABLE LEGAL BASIS
Purposes that apply to all Website users and related legal basis for processing
InnoSIGN collects and processes your personal data through the Website for the purposes mentioned below.
The legal basis for processing, required under GDPR, may be that such processing is needed for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, or such processing is needed as per our legal obligations, or processing is needed in the pursuit of InnoSIGN’s legitimate interests or processing is needed based on your consent.
YOUR RIGHTS AND HOW YOU CAN EXERCISE THEM
Your rights include the following:
Right of access
You have the right to obtain confirmation from us as to whether or not we process personal data about you, and, where this is the case, access to your personal data.
You have the right (as far as this does not adversely affects the rights and freedoms of others) to obtain a copy of your personal data from us.
Right to rectification
You have the right to ask us to rectify without undue delay any inaccurate personal data concerning you. You can also ask us to complete incomplete personal data regarding you by providing us with a supplementary statement containing such additional information.
Please note that notwithstanding the above, we are still allowed to continue storing your personal data (throughout the period of restriction) or to process your personal data for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.
If you have requested restriction of processing, we will inform you before the restriction of processing is lifted.
Right to erasure
You have the right to ask us to erase without undue delay personal data concerning you, where one of the following grounds apply:
- Your personal data are no longer necessary in relation to the purposes for which they were processed;
- You have withdrawn your consent – for those processing activities based on your consent – and we have no other legal ground for such processing;
- You object to the processing of your personal data (for more information on the right to object, see further below) and there are no overriding legitimate grounds for such processing;
- Your personal data have been unlawfully processed;
- Your personal data must be erased for compliance with a European or European Member State legal obligation to which InnoSIGN is subject.
Please note that your right to erasure will not apply to the extent that processing is necessary for:
- exercising the right of freedom of expression and information;
- compliance with a European or European Member State Law to which InnoSIGN is subject;
- reasons of public interest in the area of public health in accordance with article 9(2)(h) and (i) GDPR as well as article 9(3) GDPR;
- archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with the relevant provisions of the GDPR;
- the establishment, exercise or defense of legal claims.
Right to restriction on processing
You have the right to obtain from InnoSIGN restriction of processing by InnoSIGN of your personal data where one of the following applies:
- You contest – in good faith – the accuracy of personal data regarding you and held by us, in that case the restriction of processing will apply for a period enabling us to verify the accuracy of your personal data;
- The processing is unlawful and you oppose the erasure of your personal data and request restriction of their use instead;
- We no longer need your personal data, but you require them for the establishment, exercise or defense of legal claims;
- You have objected to the processing of your personal data by InnoSIGN in accordance with the relevant GDPR provision, in that case the restriction of processing will apply for a period enabling us to verify if our legitimate grounds override yours.
Please note that notwithstanding the above, we are still allowed to continue storing your personal data (throughout the period of restriction) or to process your personal data for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.
If you have requested restriction of processing, we will inform you before the restriction of processing is lifted.
Right to data portability
You have the right (insofar this does not adversely affects the rights and freedoms of others) to receive the personal data concerning you, that you have provided to InnoSIGN, in a structured, commonly used and machine-readable format and to transmit those data to another controller, without hindrance from InnoSIGN, where the processing is:
- based on your consent or on a contract; and
- carried out by automated means
Right to objection to processing
You have the right to object at any time, on grounds relating to your specific situation, to the processing of your personal data by InnoSIGN which is based on InnoSIGN’s pursuit of its legitimate interests as a controller. In that case InnoSIGN will no longer process your personal data, unless:
- InnoSIGN demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms; or
- For the establishment, exercise or defence of legal claims.
You have the right to object at any time to the processing of your personal data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing. If you sign up to any of our alerts or newsletters, you will also have the opportunity to directly un-subscribe from this service by clicking on the unsubscribe link in the relevant alert or newsletter.
Right to withdraw consent
Where the processing is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on your consent before its withdrawal.
MORE DETAILS ON HOW WE PROCESS YOUR PERSONAL DATA
Categories of personal data we collect about you and retention periods
InnoSIGN obtains your personal data through your use of the Website (e.g. through cookies), as well as directly from you, if you choose to disclose personal data to InnoSIGN, as will be further detailed below.
Who we share your personal data with
We will disclose your personal data only as described in this Policy (including any updates to this Policy, as will be notified to you from time to time as set out above under “The reason behind this Privacy Policy”).
Subsidiaries/affiliated companies and third party processors
InnoSIGN transfers or discloses your personal data to its subsidiaries/affiliated companies and to third party service providers processing personal data on InnoSIGN’s behalf for the purposes set out above.
Third party service providers may include IT services and website hosting companies, (internet) connectivity providers, provider of data analytics and tracking services, providers of press release and newsletter distribution networks, as well as service providers that provide technical and administrative support for the Website and underlying IT systems. These service providers may provide their services from locations within the EU and outside of the EU.
Other third parties include regulatory and government agencies (see further below in this Policy), and potentially, third parties with whom InnoSIGN may merge or which may be acquired by InnoSIGN (see further below in this Policy).
Compliance with laws and legal proceedings
InnoSIGN will disclose your personal data where:
- InnoSIGN is required to do so by applicable law, by a governmental body or by a law enforcement agency.
- To establish or exercise our legal rights or defend against legal claims;
- To investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies or as otherwise required by law.
Other
If a third party acquires all (or substantially all) of our business and/or assets, we will disclose your personal data to that third party in connection with the acquisition. However, such disclosure will occur subject to and in accordance with applicable data protection laws.
Types of Personal Data and Retention Periods
We may process the following categories of personal data, and retain the personal data for the periods indicated.
| Type of personal data | Description | Retention period |
| Master Data | Data needed to identify you in our system, general identification details, contact details, professional details, country specific identifiers | 36 months |
| Activity Data | Data relating to our professional interaction with you, topics discussed and the like | 60 months |
| Consent Management Data | Data with you have freely given with your consent signifying your agreement for us to process your personal data | 120 months |
Our retention periods are dictated by applicable statutory/legal requirements, industry guidelines and, for those data categories for which no express statutory or legal requirements apply, certain other determining factors, including but not limited to, the need to prove or enforce a transaction or contract, or to enforce our policies.
International transfers
InnoSIGN may transfer your personal data to its affiliates, including our affiliates outside of the EU in accordance with applicable law.
InnoSIGN may also transfer your personal data to certain third party service providers both within and outside of the EU.
Who We Are and How You Can Contact Us
“InnoSIGN” or “we” means InnoSIGN B.V., a Dutch company with registered office at High Tech Campus 11, 5656 AE Eindhoven, the Netherlands.
As data controller we respect your right to privacy. We will only process your personal data as described in this Policy and in accordance with the relevant data protection legislation, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or “GDPR”).
At InnoSIGN we have a data protection officer, who can be contacted by any of the following means for any privacy-related questions, including regarding how we collect, store and use your personal data:
- E-mail: oncosignal@innosignbio.com; or
- Postal mail:
InnoSIGN B.V.
For the attention of the
Data Protection Officer
High Tech Campus 11
5656 AE Eindhoven
The Netherlands
Telephone: +31 85 0685502
How to exercise your rights
If you wish to exercise any of the rights mentioned at the left, please contact InnoSIGN’s Data Protection Officer by e-mail at oncosignal@innosignbio.com or otherwise reach out to us by postal mail at InnoSIGN B.V., for the attention of the Data Protection Officer, High Tech Campus 11, 5656 AE Eindhoven. Please clearly identify the right(s) you wish to exercise and include your contact details (including a valid e-mail or postal address) so that we can respond to your request. Please note that you may be asked to provide proof of your identity so that we are able to verify that the request relates to you.
Right to lodge a complaint with supervisory authority
In accordance with article 77 GDPR you have the right to lodge a complaint with a supervisory authority, in particular in the European Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that InnoSIGN’s processing of your personal data infringes the GDPR.