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Privacy Policy

Last Updated March 2024

Crown Bioscience, Inc. and its subsidiaries (collectively "Crown Bioscience", “we”, “us”, or “our”) are committed to protecting your privacy and making it easier and more efficient for you to interact with us. We recognize that it is critical for you to be confident that your personal data is protected when you visit our website, use our products and services, and communicate with us. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal data through our website, products, services, and communication tools (together "Crown Bioscience Services"). By using Crown Bioscience Services, you consent to our collection, processing and use of your personal data as described in this Privacy Policy.

Controller of Personal Data

Any personal data provided to or collected by Crown Bioscience is controlled primarily by Crown Bioscience, Inc.,16550 West Bernardo Drive, Building 5, Suite 525, San Diego, CA 92127, United States, as the “Controller” for purposes of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, or “EU-GDPR”).

What Personal Data We Collect

Crown Bioscience, including its affiliates, is in the business of providing research and development services to the biotechnology and pharmaceutical industries. In general, our collection, processing, and use of personal data pertains to the growth and operation of our business. Crown Bioscience does not collect any personal data about you unless you provide that information voluntarily by filling out a form, interacting with a chat bot, sending an email, placing an order, applying for an employment opportunity, or accessing your account. You are under no obligation to provide us with personal data of any kind; however, your refusal to do so may prevent you from using certain features of Crown Bioscience Services.

The personal data we may collect includes:

Personal Data

  • Personal identifying information such as your name, address, email and phone number;
  • Your employer and job role;
  • Your location information;
  • Your areas of interest relating to our products, services or businesses; and
  • Content of your reviews, emails and online chat or messages with us. The information collected is not limited to text characters and may include audio, video, and graphic information formats included in the message.

Derivative Information (Log Data)

Our servers may automatically collect information about your use of our website, such as:

  • IP address used to connect your computer to the internet;
  • Login information, email address, and password;
  • Location of your device or computer and your access time;
  • our browser and operating system;
  • Webpage visit and content use history, including full URL clickstream to, through, and from our website, as well as date and time, products and content you viewed or searched for, content downloads, streams, and playback details, download errors, length of visits to certain pages, and page interaction information; and
  • Crown Bioscience Services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, your settings preferences and backup information, information about uploaded files such as the file name, dates, times and location).

No Collection of Children's Personal Data

Crown Bioscience does not knowingly collect personal data from children under the age of 13 or create profiles of children under the age of 13. Users are cautioned, however, that the collection of personal data submitted in an email will be treated as though it was submitted by an adult. If you become aware of any data we have collected from children under age 13, please contact us at DPO_Ext@crownbio.com.

Purpose of Using Your Personal Data

Having accurate information about you allows us to deliver, develop, and improve Crown Bioscience Services and provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you to:

  • Communicate with you via different channels (e.g., by phone, email, or live chat) to address your questions and concerns; (Legal basis for processing your personal data: consent, performance of contract and/or to take steps at your request prior to entering into a contract, in accordance with EU-GDPR Art. 6 Section 1(a), (b))
  • Ensure smooth connection with and proper function of our website and optimize user experience of our website. The log files enable the evaluation of system security and stability; (Legal basis for processing your personal data: legitimate interest for running our business, provision of administration and IT support, and developing our products/services, in accordance with EU-GDPR Art. 6 Section 1(f))
  • Verify and/or authenticate your identity, access rights, privileges, etc; (Legal basis for processing your personal data: performance of contract, legitimate interest for network security and to prevent fraud, in accordance with EU-GDPR Art. 6 Section 1(b), (f))
  • Deliver, fulfil and manage Crown Bioscience Services and other transactions; (Legal basis for processing your personal data: performance of contract, in accordance with EU-GDPR Art. 6 Section 1(b))
  • Improve Crown Bioscience Services, troubleshoot and solve problems, and analyse usability and effectiveness; (Legal basis for processing your personal data: legitimate interest for running our business, provision of administration and IT support, and developing our products/services, in accordance with EU-GDPR Art. 6 Section 1(f))
  • Understand your needs and identify your preferences so as to recommend features, products, and services that might be of interest to you; (Legal basis for processing your personal data: legitimate interest to study how customers use our products/services, to develop them and grow our business, in accordance with EU-GDPR Art. 6 Section 1(f))
  • Deliver targeted advertising, newsletters, marketing, events and other information that might be of interest to you, provided that you have not objected to them and you may always object to such use of your personal data by unsubscribing the marketing communications; (Legal basis for processing your personal data: legitimate interest to study how customers use our products/services, to develop them and grow our business, in accordance with EU-GDPR Art. 6 Section 1(f))
  • Comply with legal obligations, such as assisting law enforcement and responding to subpoena. We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (Legal basis for processing your personal data: legal obligation, in accordance with EU-GDPR Art. 6 Section 1(c))
  • Prevent misuse and misbehaviour, monitor against theft, and protect against criminal activity; (Legal basis for processing your personal data: legal obligation, legitimate interest for network security and to prevent fraud, in accordance with EU-GDPR Art. 6 Section 1(c), (f))
  • Use depersonalised and aggregated information to develop reports and analysis for research and for other legitimate business purposes. We combine your data, in aggregated form, with those of other users to generate summarised reports that help us to optimise our services and products. (Legal basis for processing your personal data: consent, legitimate interest to develop our business and to inform our marketing strategy, in accordance with EU-GDPR Art. 6 Section 1(a), (f))
Ways We Collect and Use Personal Data, and Your Options

Contact Form(s)/Contact by Email/Live Chat

If you send us inquiries or requests via our contact forms, email or live chat, or register for a webinar or event, your details, including the contact information you have provided there, will be stored for the purpose of processing the inquiry and fulfilling the request and for follow-up actions.

Online Account

We provide an online database for users to search relevant information of our models. To access the database, you will need to create an account and provide us with personal data that includes your name, company, email, and a password. Your personal data will be used to verify and/or authenticate your identity, access rights, privileges, etc. Your refusal to provide personal data will prevent you from using the database.

Job Application Form

If you apply for a job with us through our website, you will need to register and create a user profile. We collect and use the following personal data during registration and setup:

  • First name
  • Last name
  • User's email address
  • Date and time of registration

Additional information can be provided voluntarily (e.g. phone number). Information required for the purpose of registration are marked with an asterisk in the input mask as a mandatory field. With your user account, you will have the possibility to search for and apply for jobs at Crown Bioscience. Your data will be deleted when your user account is closed and if no legal retention obligations exist. You can usually change and/or delete your user account, including the data you have provided, directly in your user account after logging in or by sending a message to our Human Resources Department at careers@CrownBio.com.

Cookies

We may use cookies created by our website to help customize and improve your experience. A cookie is a unique text file stored on your computer by your web browser. These text files are used as a means of distinguishing among users of a website. A cookie will not include personal data, unless you have volunteered that information. One of the primary purposes of cookies is to provide a convenience feature to save your time. For example, if you personalize pages on our website or register for a service, a cookie helps us to recall your specific information during subsequent visits. When you return to the website, the information you previously provided can be retrieved from the cookie file, allowing you to easily use customized features.

You have the ability to accept, change or decline cookies by clicking “Accept / Save Settings” on our webpage. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer (or delete cookies already present). If you choose to decline cookies, you may not be able to fully experience certain features of our website.

We may also partner with selected third-party vendors, such as HubSpot and Google Analytics, to allow tracking technologies and remarketing services on our website through the use of first-party cookies and third-party cookies. If you consent to these cookies, the information collected in connection with your use of our website will be evaluated for statistical purposes with the aim of optimizing our website and services, improving your experience on our website and will not be used to find out your personal identity. 

HubSpot

Our website uses HubSpot, a marketing automation tool that allows us to accept forms and respond to our users with the content they request. HubSpot uses cookies to help gauge the interest of our users, make repetitive tasks easier, serve personalized content, and facilitate our marketing. You consent to accepting HubSpot cookies when you visit our website. To reject cookies from HubSpot, you can turn them off in your web browser.

Google Analytics

Our website uses Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses cookies. The information generated by the cookies about your use of our website is usually transferred to a Google server in the United States and stored there. We use Google Analytics only with IP anonymization enabled. This means that Google will truncate the IP address of users within Member States of the European Union or in other signatory states to the Agreement on the European Economic Area to exclude any personal relationship. You can prevent Google from collecting the data generated by the cookies and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at http://tools.google.com/dlpage/gaoptout.

Newsletter and Marketing Communications

You will receive marketing communications from us if you have:

  • subscribed to our newsletter;
  • registered for our webinars or other events; or
  • used or expressed an interest in our products or services.

We rely on legitimate interest to continue sending you marketing communications to let you know of our products or services or any events that we are running. In addition to the email address required for sending the newsletter, we store the IP address via which you have registered for the newsletter as well as the date and time of registration so that we can trace any possible misuse at a later point in time. You can opt-out from receiving marketing emails from us by un-subscribing at this link http://info.crownbio.com/hs/manage-preferences/unsubscribe-simple, or by following the links at the bottom of any of our marketing emails you may receive. After your cancellation, your email address will be deleted from our newsletter distribution list immediately.

Retention of Personal Data Collected

The personal data collected by Crown Bioscience is retained by Crown Bioscience as determined by relevant legal retention periods. Personal data stored in your account will be retained until you choose to remove it or until the account is closed. We retain your personal data for as long as is necessary to fulfil the purpose for which it was collected. We may retain your personal data for longer period due to reasons such as security and fraud prevention, tax or accounting record keepingWhere we process your personal data based on your consent, your consent in such case is optional and you may also withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal., or complying with legal or regulatory requirements.

Where we process your personal data based on your consent, your consent in such case is optional and you may also withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

If you withdraw your consent or object to the data processing, your data will no longer be processed for the respective purposes and will be erased in accordance with our internal policies. Should it not be possible to erase your data entirely (e.g. due to compliance reasons), processing of your personal data will be restricted to necessary purposes.

Confidentiality and Security of Personal Data Collected

Crown Bioscience is strongly committed to protecting personal data against unauthorized access, use or disclosure. Consequently, Crown Bioscience limits employee access to personal data to only those employees who need access to the information in the performance of their official duties. Employees who have access to such information follow appropriate protocols in connection with the use and disclosure of personal data. Additionally, Crown Bioscience has implemented measures to safeguard the personal data and to improve the security of its information technology, including, but not limited to, authentication, authorization, monitoring, auditing, and encryption. These security measures have been integrated into the design, implementation, and day-to-day operations of our website as part of our continuing commitment to the security of electronic content as well as the electronic transmission of information. For website security purposes and to maintain the availability of our website to all users, Crown Bioscience employs software to monitor traffic to identify unauthorized attempts to upload or change information or otherwise damage our website.

While we use administrative, technical, and physical security measures to help protect your personal data and have taken reasonable steps to secure the personal data you provide to us, please be aware that despite our efforts, no security measures or systems are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, absolute security is not guaranteed if you provide personal data.

Transfer of Your Personal Data to Third Parties

We may share the data collected about you with third parties in certain situations:

  • If we believe the release of the data about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your data as permitted or required by any applicable law, rule, or regulation.
  • We may share your data with third-parties suppliers that perform services for us or on our behalf, including data analysis, email delivery, technical support, hosting service, customer service, payment, and marketing assistance.
  • We may share your data with our affiliates who honor this Privacy Policy in connection with the purposes described above. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • We may share your data with our business partners to offer you certain products, services or promotions.
  • Some Crown Bioscience products and/or services may be co-branded and offered in conjunction with another entity. If you register for or use such products and/or services, both Crown Bioscience and the other entity may receive information collected in connection with the co-branded product/services.
  • If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your data to the successor entity. If we go out of business or enter into bankruptcy, your data would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline to honor commitments we made in this Privacy Policy.

Your voluntary provision of personal data to Crown Bioscience constitutes your consent to the collection and disclosure of your data by Crown Bioscience for the above purposes. In other situations, we will notify you when personal data about you might be shared with third parties, and you will have an opportunity to choose not to share the information. As far as we transfer data to our service providers and/or affiliated entities as described above, they are contractually bound to data protection agreements in addition to mandatory laws.

It should be noted however, when you post comments, contributions or other content to our website or during a webinar, your posts may be viewed by all users and may be publicly distributed outside our website permanently. We are not responsible for the actions of third parties with whom you share personal or sensitive information, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

International Data Transfer

We may transfer to, and store the data we collect about you in, countries other than the country in which the data was originally collected, including the United States or other destinations outside the European Economic Area (“EEA”) and the United Kingdom. Those countries may not have the same data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA and outside the United Kingdom.

If you are located in the EEA or the United Kingdom, we will only transfer your personal data if:

  • the country to which the personal data will be transferred has been granted a European Commission adequacy decision; or
  • we have put in place appropriate safeguards in respect of the transfer, for example we have entered into European Union Standard Contractual Clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by a European Union or United Kingdom supervisory authority. You may also refer to the section below titled EU, UK, and Swiss Residents to read about our compliance with the Data Privacy Framework.

You may request more information about the safeguards that we have put in place in respect of transfers of personal data by contacting us at DPO_Ext@crownbio.com.

Access to and Change of Your Information and Privacy Preference

You may submit a request to Crown Bioscience to inquire whether personal data pertaining to you has been collected. Any such request shall be made in writing and must be accompanied by reasonable proof of identity of the user. Reasonable proof of identity may include verification of a signature, inclusion of an identifier generally known only to you, or similar appropriate identification. Please submit your request to: DPO_Ext@crownbio.com. Crown Bioscience will undertake reasonable steps to permit you to correct, amend, or delete your data demonstrated to be inaccurate or incomplete.

Account Information

You may at any time review or change the information in your account or terminate your account by:

  • Logging into your account settings and updating your account; or
  • Contacting us at DPO_Ext@crownbio.com.

Upon you request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our contractual rights and/or comply with legal requirements.

Cookies

If you want to browse our website without being tracked the browsing history, you may do so by blocking cookies on your browser.

Emails and Communications

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

Links to Third-Party Websites

Our website may provide links to third parties as a convenience in locating relevant information and services. We do not take any responsibility for the content, the accuracy of the information and/or quality of products or services provided by or advertised on these third-party websites. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from our website.

Your Data Protection Rights

If you are a “data subject” under applicable data protection law in the EEA or United Kingdom, you will have the following rights in relation to personal data that we hold about you:

  • Right to Access - to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
  • Right to Rectification - to request that we rectify or update any personal data that is inaccurate, incomplete or outdated;
  • Right to Erasure - to request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
  • Right to Restriction of Processing - to request that we restrict the use of your personal data in certain circumstances, such as when the accuracy of the data is contested;
  • Right to Withdraw Consent - where you have given us consent to process your personal data, to withdraw your consent;
  • Right to Data Portability - to request that we provide a copy of your personal data to you in a structured, commonly used and machine-readable format in certain circumstances;
  • Right to Object - to object to the processing of your data for certain purposes; and
  • Right to Object to Automated Decision Making - We use automated decision-making and profiling on our website. You have the right to object to our use of automated decision-making and profiling. You can do so by opting-out of cookies and similar technologies in accordance with the methods described in the relevant section above.

To exercise your rights as set out above or to make a complaint or submit an inquiry about our privacy practices, please contact us at DPO_Ext@crownbio.com. You may also have the right to lodge a complaint with a supervisory authority in your country of residence. The contact information for our Supervisory Authority is listed below.

User's Responsibility

While we are committed to protecting your privacy, Crown Bioscience cannot and does not guarantee absolute privacy. You are responsible for safeguarding your passwords for access to your account and are responsible for all actions made using your password. You will not share your passwords or provide access to another individual using your password.

Data Privacy Framework - European, United Kingdom, and Swiss Residents

Crown Bioscience, Inc. and its U.S. Subsidiaries (collectively, “Crown Bioscience U.S.”, which shall include the entities Crown Bioscience, Inc., Crown Bioscience San Diego Inc., and Indivumed, Inc.) comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Crown Bioscience U.S. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. “DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Crown Bioscience U.S. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Dispute Resolution

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Crown Bioscience U.S. commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Crown Bioscience at: DPO_Ext@crownbio.com.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Crown Bioscience U.S. commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS Mediation, Arbitration, ADR Services (“JAMS”), an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

If any request remains unresolved, individuals may, under certain circumstances, have a right to invoke binding arbitration under DPF (see https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction for additional information).

Dispute Resolution

The Federal Trade Commission has jurisdiction over Crown Bioscience U.S.’ compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

Onward Transfers

For transfers of personal data to a third party acting as a controller, Crown Bioscience U.S. shall ensure that: (1) such data may only be processed for limited and specified purposes consistent with the consent provided by the individual; (2) the recipient will provide the same level of protection as the DPF Principles and will notify Crown Bioscience U.S. if it makes a determination that it can no longer meet this obligation; and (3) If the third party controller provides such notice that it can no longer meet its obligations, the third party controller must cease processing or take other reasonable and appropriate steps to remediate.

For transfers of personal data to a third party acting as an agent (processor), Crown Bioscience U.S. shall ensure that: (1) transfers are only for limited and specified purposes; (2) the agent is obligated to provide at least the same level of privacy protection as is required by the DPF Principles; (3) Crown Bioscience U.S. takes reasonable and appropriate steps to ensure the agent effectively processes the personal information transferred in a manner consistent with Crown Bioscience U.S.’ obligations under the DPF Principles; (4) the agent is required to notify Crown Bioscience U.S. if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles; (5) upon notice, Crown Bioscience U.S. will take reasonable and appropriate steps to stop and remediate unauthorized processing; and (6) Crown Bioscience U.S. will provide a summary or a representative copy of the relevant privacy provisions of the contract with the processor to the Department upon request.

Crown Bioscience U.S. remains liable under the DPF Principles if an agent processes personal data covered by this policy in a manner inconsistent with the DPF Principles, except where Crown Bioscience U.S. is not responsible for the event giving rise to the damage.

Changes to This Privacy Policy

Crown Bioscience will occasionally update this Privacy Policy to reflect changes in our practices. When changes are made to this Privacy Policy, we will revise the "last updated" date at the top of this page. We encourage you to periodically review this policy to be informed of how Crown Bioscience is protecting your data.

Disclaimer

The information provided in this Privacy Policy should not be construed as giving business, legal, or other advice, or warranting as fail proof, the security of information collected or provided through our website.

Contact Information

Controller:

Crown Bioscience, Inc.,
16550 West Bernardo Drive
Building 5, Suite 525
San Diego, CA 92127
Attention: Legal Department
DPO_Ext@crownbio.com