Privacy Policy of PROTEON PHARMACEUTICALS S.A.

Effective as at 25 May 2018
1. Introduction

On Proteon Pharmaceuticals S.A. website we wish to provide you with the best possible access to our products and information about what we do. That is why your privacy and security of your personal data will always be one of our top priorities.

Therefore, we want to clearly explain how do we collect, store, provide and use your personal data and to define the methods of controlling and identifying preferences that are available to you when providing your personal data.

That is the objective of this Privacy Policy (the “Policy”) which contains detailed information about that.

2. Information About the Policy

This Policy sets out key information regarding your relationship with respect to personal data with PROTEON PHARMACEUTICALS S.A. based in Łódź, Poland.

We may periodically prepare new offerings through the website. If introducing new or additional offerings results in the change of the method in which we collect or process your personal data, we will provide you with additional information, conditions or principles. Unless provided otherwise, any new or additional services to be introduced will be subject to this Policy.

The objective of this Policy is to:

  1. guarantee that you understand which personal data we collect with your consent and reasons why do we collect and use data and with whom do we share such data;
  2. explain how do we use personal data which you provide to us so that you can browse PROTEON PHARMACEUTICALS S.A. website with pleasure; and
  3. explain your rights and preferences with respect to personal data collected by us and the manner in which we protect your privacy.

PROTEON PHARMACEUTICALS S.A.
ul.Tylna 3A  
90-364 Łódź
 

Email address: RODO@proteonpharma.com
(+48) 42 209 33 95
(+48) 502 269 383

3. Your Rights and Preferences: Control and Choice

You may be aware that the new EU law referred to as the general data protection regulation or the “GDPR” grants certain rights to natural persons with respect to their personal data. The rights granted to natural persons which are available to the extent it is possible and except for cases where it is limited by applicable law are as follows:

  • right of access — right to being informed and to request access to personal data processed by us;
  • right to rectification — right to request rectification or update of personal data if inaccurate or incomplete;
  • right to erasure — right to request erasure of personal data;
  • right to restriction — right to request to discontinue temporarily or permanently our processing of personal data, in whole or in part;
  • right to object —
    • right to object, at any time, to our processing of personal data on grounds relating to specific situations;
    • right to object to personal data processing for direct marketing purposes;
  • right to data portability — right to request electronic copy of personal data or to transmit data to be used by third parties; and
  • right to refuse being subject to automated decision-making — right not to be subject to a decision based solely on automated process, including profiling, which produces legal effects concerning the user or similarly significantly affects the user.

In order to enable the exercise of the said rights, below please find our contact details:

PROTEON PHARMACEUTICALS S.A.
ul.Tylna 3A  
90-364 Łódź
 

Email address: RODO@proteonpharma.com
(+48) 42 209 33 95
(+48) 502 269 383

In case of any questions regarding your privacy, rights or their enforcement, please contact us. We will respond to your question within reasonable time after verifying your identity. If you are not satisfied with the manner in which we use your personal data, you may also contact and lodge a complaint with the Polish data protection authority.

4. How do We Collect Your Personal Data

We collect personal data whenever:

  1. you address a query to us — whenever you address a query to us, your specific personal data such as email address, name, possibly also (as long as given by you) your contact telephone number, as well as company details, will be collected
  2. you use this website: proteonpharma.com — whenever you use our website, we collect personal data about how you use the site such as information about product you view and time you spend on our website.

We use anonymised or aggregated information for such purposes as IT system testing, research data analysis, building marketing and promotional models, website improvements and development of new functionalities and options on the site.

5. Personal Data That We Collect

In the tables below, we list categories of your personal data that we collect and use:

Personal data collected whenever a query is addressed to us

Personal Data Category

Contact details

Category Description

These are personal data that you give in order to address a query to us. Such data includes email address, name (and also, if given by you: contact telephone number and company details).

Personal data collected whenever you use the website

Personal Data Category

Data about website use

Category Description

That is personal data collected whenever you use the website — it may include: 

  • Information about your interaction with the website, including a detailed description of the queries sent, their date and time, information about viewed content.
  • Technical data that may include URL address, data from cookies, your IP address, type of devices used by you to get access to the website or connecting thereto, unique device ID, device information, network connection (e.g. Wi-Fi, 3G, LTE, Bluetooth) and service provider, network and device efficiency, browser type, language, data enabling digital right management, operating system. Other information about technical data processed by us is available below.
6. How Do We Use Personal Data

Whenever you use or have any interaction with the website, we may use various technologies for collecting information about you for a variety of reasons. Below please find a table presenting reasons due to which we process your personal data, related legal grounds that in accordance with law enable us to process your personal data, and personal data categories that we use for such purposes:

Why PROTEON PHARMACEUTICALS S.A. Processes Your Personal Data (“Purposes of the Processing”)

To reply to queries submitted through the website and to ensure, personalize and improve the website use, for example to provide adapted, personalized, and localized content and advertising displayed through the website.

To understand how do you get access to the website and use it to ensure technical functionality and analyse the manner in which you use the website, including your interactions with advertising and products made available directly or through links or offered through the website.

To communicate with you in matters related with the website

Legal Grounds Allowing Data Processing

  • Legitimate interests
  • Legitimate interests
  • Legitimate interests

Categories of Personal Data Used For Processing

  • Contact details
  • Data about website use
  • Data about website use
  • Data about website use
7. Sharing Personal Data

Information that we may share

Categories of Recipients

Suppliers and others

Academic researchers

Law enforcement and data protection authorities

Buyers of our business

Reasons of Sharing Data

We use the services of the technical service providers that may support technical infrastructure that we need to reply to queries addressed to us through the website, in particular the suppliers that host, store, maintain and manage the website, its contents and data that we process. 

Your personal data used in such activities as statistical analysis and academic research will be disclosed only in pseudonymised form.

We will disclose your personal data if we believe in good faith that this is required of us based on our legal obligations or as a response to important legal actions such as an arrest warrant, court judgment or court summons. 

Your personal data will also be made available if we believe in good faith that it is necessary for our own purposes or legitimate interests of a third party related with national security, law enforcement, litigations, prosecution of criminal offences, protection of security of any person or protection against death or injury provided we decide that such interests override fundamental rights and freedoms in connection with which protection of your personal data is required.

Your personal data will be disclosed if we sell or agree to sell our business to a buyer or a potential buyer. 

Then, PROTEON PHARMACEUTICALS S.A. will continue to ensure confidentiality of your personal data and will send an appropriate notification before your data is disclosed to the buyer or is governed by the regulations of a different Privacy Policy.

8. Data Retention and Erasure

The user’s personal data will be stored by us for as long as it is necessary to deliver the website and for justified and necessary business  purposes such as maintaining efficiency, making decisions about new functionalities and offerings based on data, performance of legal obligations. Your personal data will be stored as long as you use the website and after addressing a query to us – in order to reply to the question and if it is related with the intention to enter into a contract with us, also in order to enter into and perform the contract and thereafter in order to perform our legal obligations and to pursue legitimate interests.

At your request we will erase or anonymise your personal data so that it cannot be used any more to identify you unless we are lawfully authorised or obliged to store personal data, including the following situations:

  • if we are obliged to retain personal data to meet legal, tax and accounting obligations, we will store necessary personal data for the period required under applicable law; and/or,
  • to protect our legitimate business purposes such as prevention of fraud or ensuring security to our users.
9. Transmission of Data to Third Countries

We may transmit your data to a third country in connection with our use of IT systems through cloud services provided that, however, the entity providing such services is recognised by the European Commission as an entity that ensures adequate level of data protection and, moreover, that in case of the transfer by the cloud services supplier to a third party that does not ensure adequate level of protection, it will make assurances about proper and relevant safeguards. You can obtain a copy of transmitted data or information about the place where data is provided.

10. Links

It is possible that we will display third party advertising and other content containing links to third party websites. We cannot control contents offered by third parties or their privacy policies; also we cannot be responsible for them. If you click on a third party link or advertising, please remember that you are leaving the website, and any personal data that you will provide will not be governed by this Policy. You should familiarise yourself with the third party privacy policies in order to find out how personal data of users is collected and processed.

11. Security of Personal Data

It is our objective to protect personal data of our users. We implement adequate technical and organisational measures to protect your personal data, however, remember that no system is ever completely safe. We have implemented various rules such as pseudonymisation, encryption, policies governing access and storage to protect against unauthorized access and unnecessary storage of the user personal data in our systems.

12. Cookies

Cookies are text files stored on your device when you visit a website. Cookies help entities that make websites available to recognise your device. Find more about cookies at: www.allaboutcookies.org or www.youronlinechoices.eu.

In fact a “cookie” defines a broad range of technologies, including:

– pixel tags (transparent graphic tags on a website or in email communication which generate information about visiting the site or reading an email),

– mobile device identifiers, and

– website data storage function used by computer software or mobile devices.

A “cookie” will be used in this Policy to describe all such type of technologies but we will attempt to present detailed information about them to enable you to make informed choices regarding cookie settings.

Cookies have different tasks such as efficient navigation between the sites, remembering preferences and generally they contribute to improving the user experience. They may also assist you in selecting appropriate advertising displayed when browsing websites in compliance with your preferences and interest.

There are a few categories of cookies, including:

Session and Permanent Cookies.

Session cookies – are cookies which are no longer valid after you close the browser; and

Permanent cookies – are cookies which remain on the device for some time or until removed.

Own and Third Party Cookies

Own cookies – are cookies placed through a website that you visit at a given time, by us or by a third party upon our request;

Third party cookies – are cookies placed by an entity other than the website that you visit. If you visit www.proteonpharma.com, and other entity places cookies through this website, this cookie will be a third party cookie.

We can also differentiate between cookies depending on their purpose, including:

Necessary Cookies

Such cookies are necessary to enable the use of our website. Without such cookies, some of the services may not be delivered.

In summary, such cookies enable the use of certain functions chosen by you and enable the provision of our products and services.

Performance Cookies 

These are cookies which provide us with information about how our services are used by visitors, e.g. which sites are visited most frequently, information about most frequent errors occurring on the sites. These cookies anonymously collect information about the visited sites. All information collected in such files is combined thanks to which they become anonymous. It is used only in order to improve our services.

This category includes the web analysis which uses cookies in order to collect data to facilitate website operation. They may be used to test projects and ensure a form adapted to the user. This category does not include cookies used by the providers of behavioural/ targeted advertising.

Functional Cookies     

Such cookies enable the website to save user settings (user’s name, language, location) and help to facilitate and better adapt the services. Such cookies also enable remembering all changes made by the user, e.g. size and font change in the text and other elements of the website that may be personalised. Data collected by such files may be anonymised and cannot be used to monitor action on other websites.

Such cookies enable remembering selected choices to improve the comfort of use.

If the cookie alone is used to re-target, it has to be also included in the category of “Cookies Related to Advertising and Its Recipients”. This may also include cookies that are used for a specific purpose and if this function includes cookies used by the providers of behavioural/targeted advertising, they must be also included in the category of “Cookies Related to Advertising and Its Recipients”, as well as in this category.

Cookies Related to Advertising and Its Recipients     

Such cookies are used to provide you with advertising which better suits your interest. They are also used to limit the frequency with which you see the same advertising and to assess the effectiveness of advertising campaigns. Usually, they are placed by advertising networks upon the consent of the website operator. They remember your visits and thereafter send this information to organisations such as advertisers. Often such files are related to the functionality of the sites placed by such organisations.

Such cookies collect information about your practices in the web to better adapt advertising to your interest.

Cookie Setting Management

Browser Cookies

You can withdraw or modify your consent to the use of cookies at any time. If you do not wish to receive cookies you may change your browser settings to accept, block or remove cookies. To do this, follow instructions provided in your browser (usually in the settings on “Help”, “Tools” or “Edit” sites).

Remember, if you set your browser to block cookies, it will not be possible to fully use all the functionalities of the website. More information is available at: www.allaboutcookies.org.

13. Amendments to the Privacy Policy

We may periodically amend the provisions of the Policy.

In case material amendments are made to this Policy, we will notify you clearly and in a manner suitable for given circumstances, e.g. by displaying well visible information on the website or by sending you an email. In some instances we will notify you in advance.

That is why we would like to ask you to read such notifications with attention.

14. Contact Details

Thank you for reading our Privacy Policy. In case of any additional questions regarding the Policy, please contact us at:

PROTEON PHARMACEUTICALS S.A.
ul.Tylna 3A  
90-364 Łódź
 

Email address: RODO@proteonpharma.com
(+48) 42 209 33 95
(+48) 502 269 383