About this Privacy Notice#
This privacy notice is intended to assist website visitors, online enquirers, subscribers and other general business contacts who interact with Comanche Biopharma in understanding how we collect, use, protect and transfer your Personal Data. It also explains how you can exercise your privacy rights and contact us.
Comanche Biopharma Corp. is a clinical-stage biopharmaceutical company. In this Notice, Comanche Biopharma Corp. and its affiliates are collectively referred to as “Comanche Biopharma”, “we”, “our” or “us”. We are committed to protecting the privacy and security of your Personal Data. This Notice covers your use of comanchebiopharma.com, website enquiries, subscriptions and general business interactions. It does not replace privacy information provided for clinical-trial participation, healthcare-professional relationships, recruitment or employment where a more specific notice applies.
Who is the controller of your Personal Data?#
For the purposes of applicable Data Protection Legislation, Comanche Biopharma Corp. is the controller of Personal Data processed in connection with the Comanche Biopharma website and general website enquiries, unless a particular form, service or communication identifies another Comanche Biopharma affiliate as the controller.
Where the European Union (EU) GDPR applies, we process Personal Data in accordance with Regulation (EU) 2016/679 and applicable national data-protection law. Where UK law applies, we process Personal Data in accordance with the UK GDPR and Data Protection Act 2018, as amended; the Privacy and Electronic Communications Regulations 2003 (PECR) also apply to certain cookies and electronic communications.
What Personal Data do we collect?#
| Category | Examples |
|---|---|
| Identity and contact information | Name, title, organisation, business role, postal address, email address and telephone number where you provide them. |
| Enquiry and correspondence information | The content of messages, questions, feedback or requests you send to us and our responses. |
| Technical and usage information | IP address, device and browser information, pages viewed, links clicked, timestamps, diagnostic data and similar information generated when you use the website. |
| Cookie and preference information | Cookie identifiers, consent choices, language or functionality preferences and analytics information, depending on the choices you make in our cookie settings. |
| Business relationship information | Your organisation, role, professional contact details and records of relevant business interactions. |
| Marketing preferences | Your communication preferences, opt-ins, opt-outs and suppression records. |
Please do not send detailed health, genetic or other sensitive medical information through a general website contact channel unless Comanche Biopharma has specifically directed you to use that channel for that purpose.
How do we collect your Personal Data?#
We collect Personal Data directly from you when you use the website, submit a form, contact us, register a preference or communicate with us. We also collect technical information automatically through the website and, where permitted, cookies and similar technologies. Business-contact information may also come from your employer or organisation, professional or public sources, service providers or existing business partners.
How do we use your Personal Data and what are our lawful bases?#
| Purpose | Typical lawful basis where EU/UK law applies |
|---|---|
| Operate, maintain and secure the website and its technical functions. | Legitimate interests in providing a secure and functional website; legal obligation where a specific security duty applies. |
| Respond to questions, enquiries, feedback, complaints and privacy requests. | Legitimate interests in communicating with website users; steps before entering a contract where the enquiry relates to a requested transaction; legal obligation for certain rights requests. |
| Manage business relationships and corporate communications. | Legitimate interests in running and developing our business; performance of a contract only where you personally are party to the relevant agreement and the processing is necessary to enter into or perform it. |
| Send scientific, corporate or other marketing communications. | Consent where required by electronic-marketing law; otherwise legitimate interests where permitted. You can opt out at any time. |
| Use non-essential analytics, functionality or advertising technologies. | Consent where required. In the UK, certain limited-purpose technologies may be used without consent where a statutory exemption applies; our cookie controls reflect the configuration used on the live website. |
| Comply with law, establish or defend legal claims, and prevent or investigate misuse. | Legal obligation and/or legitimate interests in protecting our rights, systems and business. |
Cookies and similar technologies#
Comanche Biopharma uses a consent-management platform on its website. You can use the live Cookie Settings control to see and manage the categories and technologies currently configured on the website. The information shown there should be read together with this notice.
Strictly necessary technologies#
These technologies are used where necessary to provide the website, maintain security, remember privacy choices or deliver a service you request. They do not require consent where an applicable legal exemption applies.
Functionality and analytics technologies#
These technologies can remember choices, measure use of the website or help us improve performance. We use them in accordance with applicable cookie rules and the choices available through Cookie Settings. In the UK, a limited statistical or appearance/functionality exception may apply only where the statutory conditions are met. Where we rely on such an exception, we provide clear information and a simple, free way to object; for the statistical exception, the sole purpose must be to produce statistics to improve the service.
Advertising or social-media technologies#
If enabled on the live website, these technologies may be used to support content, advertising or social-media functionality. We do not activate a technology for a purpose that requires consent until valid consent for that purpose has been obtained. Where applicable law provides an opt-out rather than a consent requirement, we provide the relevant choice in connection with that processing.
Special Category Personal Data#
The general website is not designed to collect Special Category Personal Data. If you voluntarily provide sensitive information in an enquiry, we will use it only where necessary and where an applicable legal condition permits us to do so, or we may ask you to use a more appropriate secure channel.
Information about other people#
If you provide Personal Data about another person, please make sure that you are entitled to do so and, where required, that the person has been given appropriate information about the disclosure.
Who do we share your Personal Data with?#
We may share Personal Data, where necessary and lawful, with:
- other Comanche affiliates;
- website hosting, cloud, IT, security, analytics, communications and professional-service providers;
- business partners where needed to respond to or manage an enquiry;
- regulators, courts, law-enforcement bodies and other authorities where required or permitted by law;
- professional advisers such as lawyers, auditors, insurers and accountants; and
- prospective purchasers, investors or transaction counterparties in connection with a corporate transaction, subject to appropriate confidentiality arrangements.
International transfers#
Comanche Biopharma operates internationally and uses service providers in multiple countries. Your Personal Data may therefore be transferred to, or accessed from, a country outside the country in which it was collected.
Where EU/EEA transfer restrictions apply, we use a mechanism permitted by the EU GDPR. Depending on the destination and recipient, this may include an adequacy decision, the European Commission Standard Contractual Clauses or another lawful safeguard. Where required, we assess whether additional measures are needed to ensure an essentially equivalent level of protection.
Where UK transfer restrictions apply, we use a mechanism permitted by UK law, such as UK adequacy regulations or an appropriate safeguard including the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. Where required, we assess the transfer against the UK statutory data protection test and apply additional protections if necessary.
You can contact our privacy contact if you would like more information about the safeguards used for a particular transfer.
How long do we keep your Personal Data?#
We keep Personal Data only for as long as needed for the purposes described in this notice and in accordance with our retention requirements. Cookie-related retention depends on the technology used and the live configuration. Routine website usage data is generally kept for shorter periods, while enquiry or business-correspondence records may be kept longer where needed to manage a relationship, meet legal obligations, or establish, exercise or defend legal claims.
Where you opt out of marketing, we may retain limited suppression information so that we can respect your preference.
How do we protect your Personal Data?#
We use appropriate technical and organisational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Measures may include, as appropriate to the processing, access controls, confidentiality obligations, security awareness, encryption where technically suitable, and incident-response procedures.
Access to Personal Data is limited to people who need it for their role. Where a service provider processes Personal Data on our behalf, we require appropriate privacy and security obligations in the relevant agreement.
What are your privacy rights?#
Depending on the law that applies and the reason we use your Personal Data, you may have the right to:
- ask whether we process your Personal Data and obtain a copy;
- ask us to correct inaccurate or incomplete Personal Data;
- ask us to erase Personal Data in certain circumstances;
- ask us to restrict processing in certain circumstances;
- object to processing based on legitimate interests and object at any time to direct marketing;
- receive or transmit certain Personal Data in a portable format where the right applies;
- withdraw consent at any time where processing is based on consent, without affecting processing already carried out; and
- lodge a complaint with a competent privacy or data protection authority at any time, however, we would appreciate the opportunity to address your concerns first, so please contact us in the first instance.
These rights are not absolute. For example, we may need to keep information where a legal or regulatory retention obligation applies. We may ask for information needed to verify your identity before responding to a request.
Where UK data-protection law applies, Comanche Biopharma will handle data-protection complaints in accordance with applicable UK requirements. You may also complain directly to the competent supervisory authority or privacy regulator. In the UK, this is the UK data-protection regulator (ICO). In the EU/EEA, you may complain to the competent supervisory authority under the EU GDPR.
Automated decision-making#
We do not currently use information collected through the general website to make decisions about you based solely on automated processing that produce legal or similarly significant effects. If this changes, we will provide the information and safeguards required by applicable law.
United States state privacy rights#
Where an applicable U.S. state privacy law gives you additional rights, these may include rights to know or access, correct, delete, obtain a portable copy, opt out of certain sale, sharing or targeted-advertising activities, limit certain uses of sensitive information, and appeal a decision on a rights request. We do not sell Personal Data for monetary consideration. Certain disclosures made through online technologies may nevertheless be treated as a “sale”, “sharing” or targeted advertising under an applicable state law. Where required by law, we provide the applicable opt-out through available website privacy controls or through the privacy contact.
Marketing and communications#
Where we send direct marketing to you, we comply with the applicable rules for the communication channel and recipient. In the UK, for example, PECR rules differ for individual and corporate subscribers. We provide a clear way to opt out of marketing communications and will respect your preference.
Children and minors#
We do not intend to solicit Personal Data directly from children through our general corporate or marketing channels. Where Comanche Biopharma processes children’s Personal Data in a clinical trial, research or other patient programme, separate privacy information and safeguards apply.
Clinical trial, patient and managed-access enquiries#
Clinical trial participants and patients should use the study- or programme-specific route provided by their healthcare professional, study site or Comanche Biopharma. General website contact channels should not be used to submit medical records, genetic information, diagnostic reports or other detailed health information unless expressly requested.
Third-party websites and links#
Our website may link to websites or services operated by third parties. Their privacy practices are governed by their own notices. A link from Comanche Biopharma does not make us responsible for the third party’s privacy practices.
Changes to this Privacy Notice#
We may update this notice to reflect changes in our website, processing activities or applicable law. The current version will be published in the Privacy Centre and will show its effective date. Where a change is material and the law requires additional notice, we will provide it in an appropriate way.
Contact Us#
If you would like to exercise a privacy right, or you have a question or complaint about this notice or the way your Personal Data is processed, please contact our Data Protection Officer using the details below.
Data Protection Officer (DPO)
The DPO Centre Netherlands B.V.
Vijzelstraat 68, Amsterdam 1017HL, Netherlands
UK Representative (where applicable)
The DPO Centre Limited
50 Liverpool Street, London EC2M 7PY, United Kingdom
The Organisation
Comanche Biopharma Corp.
50 Beharrell Street, Unit B, Concord, MA 01742, United States