Last Updated: September 25, 2023
This Privacy Notice explains the practices that Sorriso Pharma Inc. (“Sorriso”, “we”, “us”) follows in connection with the Personal Data that we collect through our website, when you contact us directly and through our research.
What is Personal Data?
For the purposes of the work that Sorriso performs and the regulations that Sorriso needs to comply with, “Personal Data” refers to any information that relates to an identified or identifiable individual such as a name, email, mailing address, phone number, or any information related to an individual’s health for the purpose of healthcare research.
How we collect and process your Personal Data
Website interaction
We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, submit a job application, or request further information about Sorriso’s products and services.
We use your Personal Data to contact you in response to your job application, acknowledge and respond to your request and for any other purpose with your consent.
Clinical research
For the purpose of our research, we do not collect your Personal Data directly. Your Personal Data is collected through the partners (“Clinical Site”) that manage the clinical trials that we sponsor. They collect your Personal Data as a participant of the clinical trial or as Clinical Site investigator or personnel involved in the clinical trial.
The patient data that we obtain and use from the Clinical Site is pseudonymized and managed through an identifier that we cannot link back to you. Only the Clinical Site that collected your Personal Data is able to link it with the identifier they provide to us. The data we obtain from the Clinical Site and process, with your consent, includes:
- An identifier to track future data against
- Data concerning your health and how you are responding to the clinical trial
- Genetic data
We use your Personal Data to review the outcomes of the clinical trial.
Information We Collect Automatically
As you navigate through and interact with our website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our website, including traffic data, logs, and other communication data and the resources that you access and use on the website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
We use your Personal Data and other information collected through the website to help us improve the content and functionality of the website, to better understand our users and to improve Sorriso’s products and services.
The technology we use for this automatic data collection is called Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
Our legal basis for processing your Personal Data
In order to comply with different privacy and data protection regulations around the world and specifically to comply with the General Data Protection Regulation (“GDPR”) in the EU and the Data Protection Act of 2018 in the UK, we require to provide a legal basis for the processing of your Personal Data.
Sorriso will not process your Personal Data unless we have a legal justification to do so. Sorriso will only process your Personal Data if:
- We or the Clinical Sites we partner with, have obtained your explicit consent prior to the processing of your Personal Data;
- If we need your Personal Data to perform a contractual obligation to which you are a party or where you have requested us to complete a contractual request;
- If we need to process your Personal Data to fulfill our legal and regulatory obligations;
- If we have a legitimate interest that will not put your fundamental rights and freedoms at risk.
Who has access to your Personal Data?
Sorriso will only disclose your Personal Data to the following parties under specific circumstances:
- To Sorriso personnel, if required, to fulfill your request;
- To service providers that support our systems or support the activities of the clinical trial, including the Clinical Sites that hold Personal Data about patients and personnel;
- To law enforcement, regulatory bodies or courts, when we are required to do so under applicable laws and regulations;
- In connection with the sale or reorganization of all or part of our business, as permitted by applicable law.
How do we keep your Personal Data safe?
Sorriso is committed to protecting the Personal Data we collect, process and disclose about you. We maintain appropriate safeguards and take reasonable steps to protect your Personal Data, ensure that we limit its use and that we disclose it only to the parties that have a legitimate reason to have access to it.
We ensure that all the parties that we disclose your Personal Data to, internal and external to Sorriso, have contractual obligations in place to protect the security and the confidentiality of your Personal Data at the same level that Sorriso does.
Where is your Personal Data stored?
Your Personal Data will be transferred to systems that reside in the US. The data will be protected at all times and pseudonymized in some cases to ensure that the risks to your privacy are minimized.
How long do we retain your Personal Data?
Sorriso and the Clinical Sites that we partner with for the purpose of clinical trials will retain your Personal Data for as long as necessary for the purpose of research, and to comply with legal and regulatory obligations.
What rights do you have regarding your Personal Data?
Subject to any exceptions provided by law, you have the right to request access to, update or delete your Personal Data.
You also have the right to request restriction of or object to the processing of your Personal Data. And you have the right to request to have your data provided to you in an electronic format if you desire to have a copy of it.
On each particular case we will inform you of the consequences of your request and if there are any exemptions to honoring your requests based on legal or contractual requirements.
During a clinical trial your rights to access, update or delete your pseudonymized Personal Data may be limited as permitted by law. Specifically, we need to process your data in specific ways in order to maintain the reliability and integrity of the study for reasons of public interest in public health and for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.
Children Under the Age of 13
We do not knowingly collect Personal Data from children under 13. Our website is not intended for children under 13 years of age. No one under age 13 may provide any information to us through our website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.
How To Exercise Your Personal Data Rights
To submit any request about your Personal Data you may contact us via email at privacy@Sorrisopharma.com.
EU/UK individuals – Right to Lodge a Complaint with a Supervisory Authority
If you reside in the EU or the UK and want to lodge a complaint with a Supervisory Authority (Data Protection Authority) you may do so in the country where you reside, where you work or where you may have experienced an issue with the processing of your Personal Data.
Changes to our Privacy Notice
It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat Personal Data, we will notify you through a notice on the website home page. The date the Privacy Notice was last revised is identified at the top of the page.
How to contact us
If you have any further questions regarding the Personal Data that Sorriso or any of our partners collect and process or if you have feedback regarding this Privacy Notice, you may contact us at privacy@Sorrisopharma.com.