1.1 This privacy notice applies to the personal data we process in relation to persons who are not employees of Destiny Pharma (referred to as “you” in the remainder of this notice). This notice sets out how and why we use that personal data, and the rights you have in respect of that personal data.
1.2 We may change this privacy notice from time to time. Where we make significant changes to this privacy notice or the way in which we use personal data within the scope of this privacy notice, we will communicate this to you via our website and/or email.
1.3 This page was last updated on 20th April 2020.
- Our Details
2.1 We are Destiny Pharma Plc, a public limited company registered in England with company number 3167025 and with our registered office at Unit 36, Sussex Innovation Centre, Science Park Square, Falmer, Brighton, BN1 9SB.
2.2 If you wish to contact us in relation to this notice, or data protection generally, please contact us by:
- email us; or
- post using our registered address stated above, marked for the attention of Privacy Officer.
- Details of processing
3.1 We use your personal data for the following purposes:
- To send you news alerts, where you have signed up to them. We use your name and email address, which we retain until you unsubscribe from our email news alerts. We rely on consent to send you our news alerts, which you may withdraw at any time using the “unsubscribe” link found at the bottom of each email newsletter we send.
- To manage our relationship with your employer. When you work for an organisation that we work with, including our suppliers, we may process: your name; your contact details; correspondence between us; and any other personal data you or your employer provides us. We process this personal data on the basis that we have a legitimate interest in managing our relationship with your employer. We will retain this personal data for so long as it is relevant to the relationship between us and your employer.
- To maintain our website. Our web server automatically collects certain information about your use of our website, for instance some key settings on your device, what type of device you are using, the operating system on your device, the website from which you came and your IP address. We process this personal data on the basis that we have a legitimate interest in ensuring our website is not abused and is optimised for the types of devices visiting it.
3.2 Other than the personal data set out above, we also collect certain non-personal data, which might derive from personal data but is not identifiable to you. Unless it is impossible to re-identify you from this information, we will treat it as personal data.
3.3 The only data that we hold about clinical trial participants is anonymised by the clinical research organisation carrying out the clinical trials before being sent to us.
- Where we obtain your personal data from
4.1 We typically obtain personal data directly from you, for instance where you submit something to our website, communicate with us, or otherwise voluntarily providing personal data to us.
4.2 Where we work with your employer, for instance where your employer supplies services to us, we may obtain your personal data from your employer.
4.3 We also collect personal data automatically when you use our website.
- People we may share your data with
5.1 In general, internal access to your personal data will be restricted to those who have a need to access it in order to carry out their duties.
5.2 We will also share your personal data with the following external third parties in some circumstances:
- regulators such as the ICO, and government authorities such as HMRC or the police, if we are required to do so by law or if the regulator or authority requests it and we regard that request as reasonable or are required to comply by law;
- our insurers, legal advisers or other third parties who need access to it in the context of managing, investigating or defending claims or complaints;
- in connection with re-organisations, mergers and acquisitions of all or part of our business;
- organisations that process your data on our behalf who are not allowed to use your data for any other purpose, for instance our web hosts;
- other companies within our group, for instance where they provide us services; and
- where you have consented to us doing so.
5.3 Where we share your personal data with our service providers, we have contracts with those service providers setting out how they must handle your personal data, including not to use your personal data other than in accordance with our instructions.
5.4 Where we have been able to fully anonymise personal data, we may share that anonymised data with third parties.
- Transfers outside of the EEA
6.1 In certain limited circumstances, we may export personal data outside of the European Economic Area for processing, and we may use third party service providers who do the same.
6.2 We only do that if there is a good reason to do it and where either:
- there are adequate safeguards in place (such as the appropriate contractual arrangements with suppliers, or adequacy decisions, depending on the destination country); or
- we are otherwise permitted by data protection law (for instance, where you consent or such transfer is necessary to provide our service to you).
- Objecting to direct marketing
7.1 Where we process your personal data for direct marketing purposes (such as our email news alerts), you can object to us doing so in one of the following ways:
- by following the unsubscribe link which we include in all electronic marketing we send; or
- by contacting us using the details at the top of this notice.
- Objecting to our legitimate interests processing
8.1 You have the right to object to processing on the basis of our legitimate interests, but, with the exception of direct marketing, we might not have to cease processing where you do so if either:
- we are able to demonstrate compelling legitimate grounds for the processing which override your interests; or
- where that legitimate interest is the establishment, exercise or defence of legal claims.
To object to legitimate interests processing, please contact us using the details at the top of this notice.
- Your rights (with effect from 25 May 2018) The law gives you certain rights in respect of the personal data that we hold, which you should be aware of:
9.1 You have the right to obtain your personal data from us except in limited circumstances. Where we provide it, the first copy will be free of charge, but we reserve the right to charge a small fee for additional requests.
9.2 You have the right to require us to rectify any inaccurate personal data we hold concerning you.
9.3 Taking into account the purposes of the processing, you may also have the right to have incomplete personal data completed, by means of providing a supplementary statement or otherwise.
9.4 You have the right to require us to erase your personal data on certain limited grounds (including where they are no longer necessary for the purpose for which they were collected or where we rely on consent, which you withdraw, and there is no other legal ground for the processing).
9.5 Where we process personal data either on the basis of consent or contractual necessity, you provided the personal data to us, and we process that personal data by automated means, you have the right to require us to give you your data in a commonly used electronic format.
9.6 You have the right to object to our processing of personal data which we process on the grounds of our legitimate interests, as detailed in the paragraph titled “objecting to our legitimate interest processing” above.
9.7 You have the right to require us to restrict the processing of your personal data on certain grounds, including where:
- you contest the accuracy of the personal data and want us to restrict processing of your personal data while we verify its accuracy;
- the processing is unlawful, but you request a restriction of the processing rather than erasure;
- we (as controller) no longer need the data for the purposes of the processing, but you have told us you require us to retain that personal data for you to establish, exercise or defend legal claims; or
- you have objected to us processing your personal data on grounds of legitimate interests and want us to restrict processing of your personal data while we consider your objection.
9.8 If you would like to exercise any of these rights, please contact us using the details set out at the top of this notice.
10.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
10.3 We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable certain key functionality of our website.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website.
10.5 Please see paragraph 3.1(d) above for information regarding our use of Google Analytics. To opt out of Google Analytics Disable Google Analytics
10.6 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
10.7 You can find out more about cookies by visiting the ICO’s website: https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies/.
- If we can’t remedy an issue you have
We hope you feel comfortable raising any issues directly with us in the first instance by contacting us using the details at the top of this page. However, should you have any complaints or issue with our treatment of your personal data, you may lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk).