Sapience Privacy Notice
Sapience Therapeutics, Inc. (also “Sapience”) recognizes the importance of protecting the privacy of the individuals we interact with through our website, direct contact and through our clinical research.
This Privacy Notice describes the practices that we follow at Sapience regarding the personal data we collect, use and disclose for our different purposes as well as how we ensure this personal data remains protected from the moment we collect it until we dispose of it. We also discuss what rights you have over your personal data and how to contact us when you have questions or concerns specific to the management of your personal data.
What is personal data?
Personal data means any information relating to an identified or identifiable individual; this refers to a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
Personal data collection and processing at Sapience
We collect and process personal data for different purposes:
- When you contact us. If you send us an email or fill our contact form on the Sapience website, we collect personal data from you such as your name, email address and the reason for your communication. We use this data to contact you back to respond to your inquiry or provide you with the information that you are looking for.
- Clinical trial. We do not collect personal data directly from the patients that participate in our clinical trials. Patient data is collected by the sites that manage the trials that we sponsor. The patient data that we obtain from the sites is pseudonymized, meaning that their identifiable information is replaced with a code that we cannot link back to these individuals.
- Clinical trial site staff and investigators. We collect personal data from these individuals to review their credentials and ensure they are qualified to perform the work related to the clinical trial.
Legal basis for processing of personal data
Sapience only processes personal data if there is a legal basis for processing. The legal bases that we rely on are:
- Legitimate interest from you. To provide you with the information you request when you contact Sapience.
- Explicit consent through the Informed Consent Form that patients sign prior to joining a clinical trial.
- Legal or regulatory obligation. Sapience needs to ensure that the staff and investigators conducting clinical trials on our behalf have the required qualifications.
Personal data disclosure at Sapience
Sapience discloses personal data to the following parties under specific circumstances:
- To Sapience’s employees in order to fulfill your request.
- To third-party service providers that support or host our systems or support activities related to clinical trials.
- To authorities as required by law, court order, legal process or government or regulatory requirement or to protect the safety, rights, or property of the public or Sapience.
- To interested parties in the event of the sale or reorganization of all or part of our business, as permitted by applicable law.
Personal data protection
Sapience is committed to protecting the personal data we collect, process and disclose. We maintain appropriate safeguards and take reasonable steps to protect 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 personal data to, internal and external to Sapience, have contractual obligations to protect the security and the confidentiality of personal data.
Personal data retention
Sapience retains personal data only for the period of time that is necessary for the purposes it was collected.
- For contact requests, Sapience retains the data 1 year after the request has been fulfilled.
- For clinical trials Sapience will retain personal data for a minimum period of 2 years. This period may be longer depending on legal or regulatory requirements.
Personal data rights
Subject to any exceptions provided by law, Sapience provides individuals with the right to exercise the following requests about personal data:
- You have the right to access the personal data that Sapience maintains about you.
- You have the right to request deletion of your personal data, update or correct your data, object to processing of your data, ask us to restrict processing of your data or request portability of your data. On each particular case we will inform you of the consequences of your request and if there are any exemptions to honoring your request based on legal, regulatory or contractual requirements.
- If Sapience has collected and processed your personal data based on your explicit consent, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing Sapience conducted prior to your withdrawal.
- You have the right to be notified about a data breach that may impact the integrity, availability or confidentiality of your personal data. Refer to our personal data breach notification section for more details.
- You have the right to complain to a data protection authority about Sapience’s collection and processing of your personal data. However, we will appreciate if you give us the opportunity to deal with your complaint internally before contacting a data protection authority.
In order to exercise any of the rights you have over your personal data please send an email to firstname.lastname@example.org. Once we receive your request, we will contact you to provide acknowledgement and request further information if required.
Personal data breach notification
We have put procedures in place 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.
Should we learn of a security breach that affects your personal data, we will notify you in order to explain how this breach may affect you and to provide you with any advice on how to protect yourself. We will contact you through the email address we have on file or by posting a notice on our website.
Sapience’s contact information
If you have any further questions about how Sapience collects, uses, discloses or protects your personal data or if you have any questions about this privacy notice, including any requests to exercise your personal data rights, you may contact us at email@example.com.