Privacy Policy - Evox Therapeutics

Evox Therapeutics Limited (company number 10076821) (also referred to as Evox/ we/ our/ us) respects your privacy and is committed to protecting your personal data.

This privacy policy will inform you as to how we look after your personal data, including when you visit our website https://www.evoxtherapeutics.com/ (Website) (regardless of where you visit it from) and when you interact with us as a Contract Research Organisation (CRO), Contract Manufacturing Organisation (CMO), supplier, collaborator, researcher, investor, shareholder, potential employee, consultant or other external, third party. It tells you about your privacy rights and how the law protects you.

This privacy policy does not apply to any other websites that you may be able to access via this Website and/or activities offered by third parties. Please ensure that you review any relevant policies on any third party websites before proceeding. We are not responsible for the collection or use of your personal data from third party websites.

Some sections of this privacy policy only apply to users in the EU/UK. We make it clear where this is the case. Countries in the EU are listed here.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

TOPICS COVERED

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED?
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS

1. IMPORANT INFORMATION AND WHO WE ARE

Controller
Evox Therapeutics Limited is the controller and responsible for processing your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Legal Department using the details set out below.

Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our Legal Department by post to Evox Therapeutics Limited, Oxford Science Park, Medawar Centre, 2nd Floor East Building, Robert Robinson Avenue, Oxford OX4 4HG, by email to Legal@evoxtherapeutics.com

Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in February 2022.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Identity Data includes first name, last name, username or similar identifier, title.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Usage Data includes information about how you use the Website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may collect special categories of personal data about you in limited circumstances. This may include visitors to out site where we may ask for limited health data as part of ensuring we maintain a safe working environment as part of the Covid 19 pandemic. We do not collect any information about criminal convictions and offences, unless this forms part of a recruitment application process.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or when you correspond with us by post, phone, email or otherwise. This includes personal data you provide when you:
- interact with us to discuss a potential collaboration and/or supply or provision of materials or services;
- where we may work with you as a consultant or a service provider to us;
- where you apply for a vacancy at Evox; or
- give us feedback or contact us.

Automated technologies or interactions. As you interact with the Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Information provided by other third parties. When you use the Website, we may receive information about that use from other companies who provide us with services in connection with it. We may receive Identity Data and Contact Data collected and stored by a cloud-based platform called Inova when you attend events or conferences. The collection of your personal data by Inova is subject to Inova’s own privacy policy (https://inova.io/privacy/).

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when we have a lawful basis to do so. Most commonly, we will use your personal data in the following circumstances and when the following lawful bases apply:

Where we need to perform the contract we are about to enter into or have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
Where we need to comply with a legal obligation.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all 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.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new business contact or collaborator	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests: – to enter into a business relationship with you
To process and deliver services or materials to you including to: (a) Deliver goods or materials;	(a) Identity (b) Contact (c) Transaction	(a) Performance of a contract with you (b) Necessary for our legitimate interests: – to protection our goods and materials and intellectual property
To answer any query you submit to us	(a) Identity (b) Contact	(b) Necessary for our legitimate interests: – to respond to the query you have submitted
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy; (b) keeping your Profile up to date (c) sharing your Contact details within Evox	(a) Identity (b) Contact (c) Profile	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests: – to keep our records updated;
To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(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 process your application for a position at Evox, including sharing within Evox	(a) Identity (b) Contact (C) Health data (d) Immigration data	(a) Necessary to comply with a legal obligation – to check you have the right to work in the UK – as part of our obligations for complying with employment laws (b) Necessary for our legitimate interests – as part of our recruitment processes Article 9 – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment
To maintain a safe working environment	(a) Identity (b) Contact (C) Health data	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests: -mitigate risk of Covid 19
To manage a contract with you relating to goods and services provided to us including payment of invoices and viability checks for setting up your company	(a) Identity (b) Contact (c) Financial data	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests: -Mitigate risks of sanction party legislation violation -checking the financial position of a company and assessing risk of payments to company

Cookies
For more information about the cookies we use, please see our cookie 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 and we will explain the legal basis which allows us to do so.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above:

carefully selected companies to operate the Website, to provide our services to you and to support our business (for example, IT database and services support);
in some circumstances, to a data protection regulator or in order to comply with the law or a legal process or where we have another legitimate interest that is not outweighed by your interests and fundamental rights (for example, to maintain the security of our computer systems);
third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Some of our service providers are based outside the UK and the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK and the EEA (the EEA includes all the countries in the EU (listed here) and also Iceland, Liechtenstein and Norway).

Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK and the EU which give personal data the same protection it has in the UK and EU.

Please contact us if you want further information regarding international data transfers.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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 business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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.

8. DATA RETENTION

How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we 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.

9. YOUR LEGAL RIGHTS (THIS SECTION ONLY APPLIES IF YOU ARE IN THE UK/EU)

If you are in the EU or UK, you have the right under EU/UK data protection laws to access personal information held about you, subject to certain conditions, and to ask for it to be changed or deleted.

If you would like to access or amend the personal information which we hold about you, or if you would like us to stop using your personal information, please contact us.

Your rights

By law you have the following rights with regard to your personal information:

Access. You have the right to obtain confirmation as to whether or not your personal information is being processed, and, if it is, request access to that personal information (commonly known as a “data subject access request”). We will need you to prove your identity before we release any personal information to you.
Correction or deletion. You have the right to ask us to correct or delete any personal information that we hold about you (unless we have the legal right to retain it). You also have the right to ask us to delete your information where you have exercised your right to object to processing (see below).
Objection. You have the right to object to processing of your information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your information for direct marketing purposes.
Restriction. You also have the right to restrict us from processing your personal information. You can ask us to temporarily stop processing information about you, for example if you want us to establish that it is accurate or the reason for processing it.
Change of preferences. You can change your information processing preferences at any time. For example, if you have given your consent to us to send you marketing material in a particular way, but have changed your mind, you can contact us or click the relevant link in any communication you receive.
Data portability. In some circumstances, you have the right to ask us transfer a copy of the personal information we hold about you to someone else.

Please note that if you ask us to stop processing your personal information in a certain way or if you ask us to delete your information, and we need to use that information to provide the Website to you, then you may not be able to continue to use them. This does not include your right to object to direct marketing, which can be exercised at any time without restriction. If you would like to exercise any of the rights mentioned above, please contact us.

The above rights do not apply to anonymised personal information.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. COMPLAINTS (THIS SECTION ONLY APPLIES IF YOU ARE IN THE EU/UK)

If, for any reason, you are not happy with the way that we have handled your personal information, please contact us.

If you are still not happy, you have the right to make a make a complaint to your local data protection regulatory authority.

If you are based in the UK, you can contact the Information Commissioner’s Office using the link here: https://ico.org.uk/global/contact-us/