Effective Date: 15 of Dec. 2020

Privacy Notice

Our responsibility:

Your integrity is important for us. Therefore, we would like to present our Privacy Policy explaining how Immuneed AB collect, manage, use, and protect your personal data that you may have provide to us. It also describes your data protection rights, including a right to object to some of the processing which we carry out.

Immuneed AB takes the privacy and security of your personal data very seriously.

Immuned AB is a privately owned company with a Swedish entity.  When we say ‘Immuneed’, ‘we’ or ‘us’ in this policy, we are referring to Immuneed AB responsible for processing your personal data.

Immuneed is a “data controller” of the personal data that we hold about you. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice. The Privacy Notice may change during the time and we will notify you of any changes where we are required to.

1. Information we collect:

Personal data 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).
We may collect, use, store and transfer different kinds of personal data about you. What information we collect will depend on your interactions with us.

2. Types of information that we may collect from you:

When you access/register to our websites, complete an online form or send us an email, we may collect and use personal data about you such as:

• Name
• Email address
• Address
• Country of residence
• Telephone number
• Technical Data including the Internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform
• Usage Data including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us;
• Other personal data you choose to provide to us when you register for our newsletters or meetings or if you correspond with us:
  • Identity and Professional Data including name, date of birth, occupation, place of work, professional background
  • Contact Data, home address, business address, email address, phone numbers
  • Transaction Data including details about payments to and from you
  • Communications Data including your preferences in receiving communications from us
  • Profile Data including your username and password, preferences, feedback, and survey responses

We may also gather personal data about you and your opinion of Immuneed, based on publicly accessible social media content you post about Immuneed and our services. Special Categories of Personal Data. We may also collect, store, and use information about your health, including any medical conditions or disabilities whether through a clinical trial program or donor program.

How do we collect your information?

The information is collected via webpages, forms and other digital and non-digital services or you may give us the information directly depending on way of contact (phone, email, letter, or other corresponding). When you visit our website and receive e-mails from Immuneed we may automatically collect technical information about your equipment, browsing actions and patterns, if you have consented to us doing this. We collect this by using cookies.

• Information provided by cookies.
  Cookies are used to improve your experience while visiting our website. Where applicable this website uses a cookie control system allowing you on your first visit to the website to allow or disallow the use of cookies on your computer/device.
• When we e-mail you, such e-mails may contain tracking facilities if you have consented to this. Activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include but is not restricted to the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates, and frequency of activity.

Information we receive about you from other sources:

• We may receive information about you from healthcare professionals because of an adverse event report.
• We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, social listening providers and credit reference agencies) and may receive information about you from them.
• We may receive information if you have provided permission to other organizations to share it with us. Before providing permission to such third-party organizations to share your personal data, you should check their privacy notices carefully.
• We may take information from publicly available sources (where possible) to keep your information up to date, for example, from the Post Office’s National Change of Address Database or any professional registration database.
• We may occasionally purchase the contact details of people who might be interested in hearing from us. Before purchasing such information, we will check with the vendor that your information was originally collected in a compliant manner, to make sure that we only contact people who have actively expressed an interest in receiving information from third parties and where it is lawful to do so.
• We may receive information about you if you apply for a vacancy at Immuneed.

How we might use your information?

We may use information held about you in the following ways:

• To respond to your requests
• To carry out our obligations arising from any contracts entered between you and us
• To conduct/be part of clinical trials or development program
• To provide you with information about our activities or about a meeting that you have signed up to
• To improve our level of service
• To notify you about changes to our service and notify you of new services
• To seek your views on our services
• To consider your application for employment
• For administrative and quality assurance purposes
• For the purposes of the establishment, exercise, or defense of legal claims
• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• To provide and improve our site to ensure that content is presented in the most effective manner for you and for your computer
• To allow you to participate in interactive features of our service when you choose to do so as part of our efforts to keep our site safe and secure
• To record, investigate and respond to complaints

Communications with you

We may text or e-mail you to provide you with information about our activities and services supplied by us. You can unsubscribe at any time by sending an email to info@immuneed.com. We may occasionally, with your consent, call you to provide you with information about our activities or provide you with information about services supplied by us. You may unsubscribe to calls by instructing the person calling you or by contacting us at any time on the details set out in the ‘Contact Us’ section of this notice. We may also communicate with you through postal marketing when it is in our legitimate interests to do this and when these interests do not override your rights. Those legitimate interests include providing you with information on our services, and other activities and those of other carefully selected organizations. You have the right to contact us at any time and opt out of receiving postal communications.

How long will we hold your information for?

We will hold your personal data on our systems for as long as is necessary to fulfil the purposes that we collected it for, including for the purposes of satisfying any legal, accounting, or other reporting requirements. By law, we are required to retain certain information for a prescribed period. In circumstances where there are no such legal requirements, to determine the appropriate retention period, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we are processing your personal data and whether we can achieve those purposes through other means. We review our retention periods for personal data on a regular basis. In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.

Your rights

You are welcome to contact Immuneed at any time to request information on how we process your personal data, access to the personal data we hold about you, to correct any mistakes or to request deletion of the same or withdraw your consent to certain types of processing of your personal data. If such a request places Immuneed in breach of its obligations under applicable laws, regulations or codes of practice, then Immuneed may not be able to comply with your request, but you may still be able to request that we block (i.e. right to object) the use of your personal information for further processing. Subject to applicable law, you may also have a right to data portability to another data controller under certain circumstances which would involve the sharing of your data with the controller in an electronic format. Subject to applicable law, you can exercise these rights for free.

Your rights include:

• transparency over how we use your data and to make a subject access request (right of access)
• a right to have your personal data updated and corrected (right of correction/rectification)
• a right to ask us to delete your information (Right to be forgotten)
• a right to ask us to stop processing your information (right to restriction)
• a right to object to (i) processing based on our legitimate interests; (ii) processing of your information for direct marketing purposes; and (iii) automated decision making and profiling (right to object)
• a right to receive a copy of your information, or have this sent to a third party (right to data portability); and
• a right to claim compensation for material or non-material damage caused if we breach the data protection rules (right to compensation)

Contact Us

If you have any questions regarding this policy or about our privacy practices, wish to exercise any of your rights or wish to make a complaint, please contact our Data Protection Officer at: info@immuneed.com

This policy was last updated in November 2020.