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Privacy Policy

SK Life Science, Inc. (“SKLSI”) recognizes and respects the privacy rights of individuals with regards to their Personal Data. This Privacy Policy (“Policy”) explains what types of Personal Data SKLSI may collect from you and applies to a variety of individuals, including employees, job applicants, customers, business contacts, HCPs, patients, and caregivers. It also explains the policies and practices that we have developed to safeguard Personal Data and to comply with applicable data protection laws. Please read this Policy carefully to understand what Personal Data we collect, how we collect it, how we use it, to whom we may disclose it, and how you can manage your Personal Data.

Separate or additional privacy policies and/or notices govern the data we obtain for employment purposes and for clinical trials, and these notices are provided when we collect that data. Clinical trial participants can access the Privacy Notice applicable to them via the Clinical Trial Study Site. Employees can access the Employee Privacy Notice via the Intranet under Human Resources.

For purposes of this Policy, Personal Data is any piece or pieces of information that can identify an individual.

  1. What Personal Data we may collect about you and why
  2. Purposes for collecting your Personal Data
  3. Your choices about processing your data
  4. Where we get information about you
  5. How we may share your personal data
  6. How we use cookies
  7. How long we keep your data
  8. How we protect your personal data
  9. Supplemental European Privacy Policy
  10. How to contact us

1. What Personal Data We May Collect About You And Why

We may collect, use, store and transfer different categories of Personal Data about you. What data we may collect depends on the relationship you have with us. We do not collect every category of information for every individual. For example, we collect financial information on employees and others to whom we make payments.

Categories of Personal Data that we may CollectDescription
IdentityFirst name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender or government-issued identification, such as driving license, passport, or government ID number.
ContactBilling, delivery or email address, phone numbers, and other contact details.
FinancialBank account and other payment-related details, tax-related information, insurance information, and payroll data.
TransactionDetails about payments to and from you and other details of products and services you have received from us.
TechnicalInternet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology, including tracking technologies like cookies and pixels, on the devices you use to access our websites or intranet.
ProfileUsername and password on our websites, or intranet, purchases, or orders made by you, your preferences, and feedback and survey responses.
UsageInformation about how you use our websites, intranet, products, and services.
Professional or Employment-relatedEmployer and employment history.
Special CategoriesDetails about your race or ethnicity, disability status, veteran status, information about your health or genetic and biometric data.

Children

While in some instances we may collect Personal Data about children with the consent of a parent or guardian, such as clinical activities or for patient support programs, we do not otherwise knowingly solicit data from, or market to, children. We do not knowingly collect Personal Data from children under the age of 13 on our websites. If we become aware that we have collected Personal Data from children under the age of 13 on our websites, we will take reasonable steps to delete it as soon as practicable. If a child provides us with this type of information on our websites, please contact us as described in Section 10 (“HOW TO CONTACT US”).

2. Purposes for Collecting Your Personal Data

We may collect and use your Personal Data when you use SKLSI or third-party operated websites and other online resources, or as part of other engagements you may have with SKLSI as described below. We may use your information for the purposes outlined below. Each purpose has the categories of data we may collect for that specific purpose.

Purpose of CollectionCategory of Data Collected
Business Operations
Engage you as a new vendor or other service provider or contractorIdentity, Contact, Financial, Transaction
Process and deliver products or servicesIdentity, Contact, Financial, Transaction
Manage our relationship with you which may include
  • Notifying you about changes to our terms or privacy policy
  • Asking you to provide feedback or take a survey
  • Responding to your requests
  • Other communications as a contractor or an employee
Identity, Contact, Financial, Profile, Usage, Employment, Special
Administer and protect our business and our intranet and websites, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of dataIdentity, Contact, Technical, Profile, Usage
Clinical Research or Patient Assistance Program
Conduct a research program, including conducting clinical trialsIdentity, Contact, Financial, Special
Providing patient assistance to start and continue on therapyIdentity, Contact, Special
Marketing and Communications
Help us evaluate, in the aggregate, and modify existing products and services and to help us develop additional products and services that are likely to be of interestIdentity, Contact, Transaction
Generate aggregate statistical studies and conduct research related to our products and services and the use of websitesIdentity, Transaction, Profile, Usage
Recognize you, as necessary, and allow you to log-on to certain pages and features for which you have registeredIdentity, Contact, Technical, Transaction, Profile, Employment
To market our product to you, based on your consent preferencesIdentity, Contact, Technical, Profile, Usage
To send you additional information about our productsIdentity, Contact, Profile, Usage
To contact you by mail, email, fax, text, telephone call for marketing purposesIdentity, Contact
Create a profile about you, which may involve artificial intelligence models, so we can better advertise and market to you unless you opt-out of such profilingIdentity, Contact, Transaction, Profile, Usage
Data analysis, to better understand how our products and services impact you and those you care forIdentity, Technical, Contact
Customer Service
Track and respond to concernsIdentity, Contact, Transaction
Further develop and improve our products and servicesIdentity, Contact
Legal and Regulatory
Comply with the law, respond to legal process, and exercise our legal rightsIdentity, Contact, Financial, Transaction, Employment, Special
Fraud preventionIdentity, Contact, Financial, Transaction, Profile
Comply with our regulatory monitoring and reporting obligations including those related to adverse events, product complaints and patient safetyIdentity, Contact, Financial, Transaction, Profile, Usage, Employment, Special

Clinical Trials

We undertake clinical trials across the globe, and we will use information from individuals’ medical records and other health data in order to improve healthcare. SKLSI contracts with service providers, such as Clinical Trial Study Sites and Contract Research Organizations (“CROs”), or other service partners, typically as data processors, to collect the Personal Data of the subjects of the clinical trial and to manage the clinical trials that we sponsor. SKLSI processes key-coded or pseudonymized Personal Data of clinical trial subjects which means that we do not have direct or immediate access to their identifiable Personal Data (except, for example, to comply with legal requirements such as those related to our pharmacovigilance obligations).

As a pharmaceutical organization, we have a legitimate interest in using information relating to your health for research studies when you agree to take part in a research study by providing your informed consent to participate. Our exception to the general provisions not to process special categories of data is that processing is necessary for scientific research purposes. This means that we will use your Personal Data when we act as the data controller for such studies, collected in the course of a research study, in the ways needed to conduct and analyze the research study. Your rights to access, change or move your Personal Data are limited, as we need to manage your Personal Data in specific ways in order for the research to be reliable and accurate. If you withdraw from the study, we will keep the information about you that we have already obtained. To safeguard your rights, we will use only the minimum Personal Data needed for these purposes. An informed consent form must be completed in order to participate in the Clinical Trial Study.

In addition, the Personal Data of potential and actual site investigators, employees or contractors may also be collected directly by SKLSI or through a CRO that we work with and is typically used, for example, to verify the individual’s qualifications, satisfy documentation requirements for the purpose of the clinical trial, to verify financial disclosures, to avoid any conflict of interest, and to otherwise conduct and analyze the research study.

For those visiting this site that provide Personal Data from within the European Economic Area (“EEA”) or the United Kingdom (“UK”), please see Section 9 (“SUPPLEMENTAL EUROPEAN PRIVACY POLICY”) for additional information.

3. Your Choices About Processing Your Data

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). We have established the following Personal Data control mechanisms.

SKLSI respects the privacy rights of individuals. Individuals can request access to the specific pieces of Personal Data SKLSI has collected, disclosed or shared about them in the last 12 months, including the categories of information, sources and business purposes of collection, as well as the categories of third parties whom SKLSI has disclosed or shared the Personal Data. You may make a request twice within a 12-month calendar year.

These rights, subject to some limitations and verification of the individual’s identity, are listed below.

  • Right to access – right to know what Personal Data we hold about you and for what purpose.
  • Right to correct – right to correct any incorrect Personal Data we hold about you.
  • Right to delete – right to request any Personal Data collected on you by SKLSI or on behalf of SKLSI to be deleted. Please note, there are some cases where we are required to keep your Personal Data, for example, a regulatory requirement or legal hold notice.
  • Right to obtain a copy of the Personal Data we have on you.
  • Opt-out of Profiling – Profiling is a form of automated decision-making that predicts certain personal aspects about someone. We may make profiles on you, using different sources, including third party sources, based on artificial intelligence models that help us determine how best we can communicate with you.
  • Opt-out of Targeted Advertising – Targeted advertising refers to displaying ads to a consumer where the ad is selected based on the Personal Data obtained from that consumer’s activities over time and across non-affiliated websites to predict preferences. We may share your information we get from cookies to third parties that may do targeted advertising.
  • Do Not Sell or Share request – Because we may share your information that we get from cookies to third parties, some laws may consider this as selling. You receive an opportunity to opt-out of the sharing of this data via the cookie pop-up tool on each website before the data is collected.
  • Limit the use of my sensitive Personal Data – We do not collect your sensitive Personal Data unless it is to fulfill the business need that we collected it for, and you have opted in to providing it. Clinical trial participants can access the Privacy Notice applicable to them via the Clinical Trial Study Site. Employees can access the Employee Privacy Notice via the Intranet under Human Resources.
  • Right to non-discrimination – right to non-retaliation for making a privacy rights request.

To make a privacy request, please fill in this form here. If you prefer to contact us via mail or email, there is contact information on the form, or you can refer to the “HOW TO CONTACT US” section at the bottom of this policy.

In order for SKLSI to process a request for you to exercise your Privacy Rights, SKLSI will verify your identity by asking you to provide certain personal information. This information may include a description of your relationship with SKLSI, your first and last name, email address, or other Personal Data that will allow us to verify your identity. If we are successful in verifying your identity, SKLSI will do its best to complete your request as soon as possible, and, in any event, no later than 45 days after receiving your request unless we request an extension. A response to opt-out requests will be made within 15 days of the request.

If we cannot validate your identity, we will attempt to contact you to inform you of this issue.

You may designate an authorized agent to exercise your Privacy Rights on your behalf in accordance with California law, if you reside in California. If you make a request through your authorized agent, we may require you to submit a written and signed statement that the agent is authorized to act on your behalf.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If you wish to appeal our action on a Privacy Rights Request, you may do so by contacting us via the information in the “HOW TO CONTACT US” section at the bottom.

Selling or Sharing Personal Data

SKLSI does not sell Personal Data. However, under certain applicable privacy laws, SKLSI’s use of tracking or targeting cookies or pixels may be considered a “sale” or “sharing” of Personal Data. We use these tracking or targeting cookies or pixels to assist us in our marketing efforts. We also use other types of cookies that are related to the performance and functioning of the website to make sure it acts as you would expect it to.

You have the opportunity to opt-out of tracking and targeting cookies, as well as performance-related cookies upon visiting our website. If you make your choice and wish to change it in the future, you may do so by clicking on the “Cookie Settings” icon on the bottom left of the website homepage.

Links to other sites

As a convenience to visitors and users of our websites, SKLSI may offer links to other sites that we believe may offer useful information. The inclusion of a link on SKLSI websites does not imply our endorsement of the linked site or service. When you click on one of these links, you will be transferred from the website and be connected to the site of the organization or company that you selected. This Policy is no longer applicable when you leave our site by way of link. Each of these linked sites maintains its own independent privacy policies and procedures, which you should consult before providing any of your Personal Data. After choosing to move to a third-party’s website, you will receive a notification that you are leaving our website.

4. Where we get information about you

Direct Interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, and e-mail or otherwise. This includes Personal Data you provide when you, for example:

  • contact us by email, phone or mail, either using the addresses or numbers posted on our websites or when you contact our employees directly;
  • interact with us via a website chatbot or artificial intelligence widget on a website;
  • apply for our products or services;
  • create an account on our websites;
  • subscribe to our services or publications;
  • request marketing to be sent to you;
  • enter a promotion or survey;
  • give us some feedback;
  • provide unsolicited information to us;
  • apply for employment or consulting opportunities with us or when you become an employee or a consultant;
  • express interest in participating in our clinical trials or other studies and programs;
  • participate in a patient assistance program; or
  • participate in a clinical trial.

Automated interactions

As you interact with our websites, we may automatically collect Technical Data about your equipment, domain name, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies. For additional information about how SKLSI uses cookies and similar technologies, see Section 6 (“HOW WE USE COOKIES”).

Third parties (or publicly available sources)

We may receive categories of Personal Data about you from various third parties and public sources as set out below:

  • Technical Data from analytics providers such as Google, advertising networks and search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers, aggregators, or recruitment agencies.
  • Identity and Contact Data from publicly available sources.
  • Special Categories of Data including Health Data from Clinical Trial Sites or Contract Research Organizations managing clinical trials on our behalf.

5. How we may share your personal data

We may share your Personal Data with the parties set out below for the purposes set out in Section 2 (“PURPOSES FOR COLLECTING YOUR PERSONAL DATA”).

  • Internal Third Parties: other companies or departments in SKLSI that, without limitation, provide IT and system administration services.
  • External Third Parties: service providers who provide services on our behalf, including without limitation, IT and system administration services and data analytics, marketing agencies, contractors and consultants. See Section 6 (“HOW WE USE COOKIES”) for an overview of how we may share your information with other third parties, including for targeted advertising.
  • Third Parties in the event of a change in business or assets: third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.
  • Professional advisers: advisors (e.g., lawyers, bankers, auditors, and insurers) who provide consultancy, banking, legal, insurance and accounting and payroll services.
  • Government Authorities: Revenue and Customs, IRS and FDA, regulators and other government agencies, regulators and authorities who require reporting of processing activities in certain circumstances.

We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

6. How we use cookies and other online tracking mechanisms

We may also collect data about your use of our websites through the use of web server logs, cookies, pixels, or other tracking technologies.

Online tracking technologies are used to track the pages of the websites you’ve visited. We may use these technologies to enable you to use certain website features, store your preferences, recognize you when you return to our websites, and monitor and maintain information about your use of our websites.

There are different categories of tracking technologies, which you may opt out of, and these are defined within the cookie tool on the website.

  • Strictly Necessary
  • Performance
  • Functional
  • Targeting
  • Social Media

The first time you visit our websites, you will be prompted to either “Allow All” cookies or “Reject All” cookies and you will have the opportunity to edit your “Cookie Settings”. The “Cookie Settings” link allows you to review information about what categories of cookies on are the site and what each category is used for. It also enables you to review the site’s Targeting and Social Media cookies, which is where we may engage in cross context behavioral advertising. You have the opportunity to opt-out before cookies or other tracking technologies can be placed. There are some cookies that are necessary to have in order for the site to operate, and these are Strictly Necessary Cookies. After you make your choice, should you wish to change your cookie preferences, you can do so by clicking the “Cookie Settings” icon on the bottom left of the website homepage.

Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Websites linked to this Privacy Policy respond to these “do-not-track” signals as well as Global Privacy Control signals via our Cookie Preference Center.

Note that linked third-party websites may also use cookies. We cannot control the use of cookies by these third-party websites. For example, when you click on a link from this site that directs you to a third-party website, that website may have the ability to recognize that you have come from our site by using cookies. If you have any questions about how third-party websites use cookies, you should contact such third parties directly.

7. How long we keep your data

We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we 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 process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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.

8. How we protect your personal data

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, except for third party targeting cookies, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures 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.

9. Supplemental European privacy policy

European Union (“EU”) Regulation 2016/679 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 (the “EU General Data Protection Regulation” or “EU GDPR”) and the United Kingdom GDPR (“UK GDPR”) (collectively, the “GDPRs”) require SKLSI as the data controller to provide additional and different information about its data processing practices to data subjects in the European Economic Area (“EEA”) or the UK. If you are a data subject within the EEA or the UK, this Supplemental European Privacy Policy applies to you in addition to the provisions above.

How we use your Personal Data

We will only use your Personal Data when the law allows us to do so. Most commonly, we will use your Personal Data in the following circumstances:

  • Where we need to perform the contract, we are about to enter or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for scientific research purposes.

We may also use your Personal Data in the following situations, which are likely to be rare:

  • Where we need to protect your interests (or someone else’s interests).
  • Where it is needed in the public interest or for official purposes.

Generally, we do not rely on consent as the only legal basis for processing your Personal Data. You have the right to withdraw consent to marketing at any time by contacting us using the contact information listed in Section 10 (“HOW TO CONTACT US”).

In the table below, we describe how we may use your Personal Data if your data is subject to the data protection laws in the EEA and UK, and which legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need additional details about the specific legal ground, we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/ActivityCategory of Personal DataLawful basis for processing
To engage you as a new vendor or other service provider or contractor(a) Identity
(b) Contact
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
     • to operate our business
To process and deliver products or services including:
(a) Managing payments, fees, and charges
(b) Collecting and recovering money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
     • to operate our business
     • to keep accurate and updated business records, and
     • to recover debts due to us.
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to provide feedback or take a survey
(c) Responding to your requests
(d) Other communications as a contractor or an employee
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Financial
(f) Professional or Employment-Related
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests
     • to keep our records updated,
     • to study how customers and clients use our products/services; and,
     • to manage our employee relationships
To enable you to complete a survey(a) Identity
(b) Contact
(c) Profile
(d) Usage
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
     • to study how customers use our products/services, and
     • to obtain feedback and grow our business.
To administer and protect our business and our intranet and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
(b) Contact
(c) Profile
(d) Technical
(e) Usage
(a) Necessary for our legitimate interests
     • for running our business,
     • provision of administration and IT services, network security,
     • to prevent fraud, and
     • in the context of a business reorganization or group restructuring exercise.
(b) Necessary to comply with a legal obligation
To conduct a research program (including conducting clinical trials)(a) Identity
(b) Contact
(c) Financial
(d) Special Categories (Health Data)
(a) Necessary for our legitimate interests
     • to develop our products
     • to facilitate and manage clinical trials
     • to conduct and analyze the research study and submit to appropriate health authorities, and
     • to improve healthcare.
(b) Necessary to comply with a legal obligation
     • to comply with safety and adverse event reporting requirements, and
     • to comply with clinical trial practice requirements
(c) Necessary for scientific research purposes

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

International transfers of Personal Data

We are based outside the European Economic Area, so the processing of your Personal Data may involve a transfer of data outside the EEA or the UK.

Whenever we transfer your Personal Data out of the EEA or the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data (i.e., adequacy decisions made by the European Commission or other regulators, as applicable);
  • We will only transfer your data to countries pursuant to binding agreement to and compliance with standard contractual clauses or binding corporate rules, each as approved by the European Commission or other regulators, as applicable;
  • We will only transfer your data to countries pursuant to the consent of the individual to whom the Personal Data pertains; or
  • We will only transfer your data to countries as otherwise authorized by the EEA or UK or permitted by applicable EEA or UK requirements.

Your data protection rights

Under certain circumstances, EEA or UK residents have the following data protection rights:

  • To access their Personal Data.
  • To correct their Personal Data.
  • To erase their Personal Data.
  • To object to the processing of their Personal Data.
  • To restrict the processing of their Personal Data.
  • To transfer their Personal Data.
  • To not be subject to a decision based solely on automated processing, including profiling.
  • To withdraw any consent that they have previously provided for the processing of their Personal Data.

If you are an EEA or UK resident and you wish to exercise any of the rights set out above, please use the link here.

You can also contact the Supervisory Authority in the country of your residence within the EEA at this link or within the UK at this link for advice or to make a complaint. Please be aware that your rights in relation to clinical research data may be limited.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated on our efforts to respond.

10. How to contact us

SK Life Science, Inc.
Privacy Office
461 From Road, 5th Floor
Paramus, NJ 07652
Email address: dataprivacy@sklsi.com
Phone number: (833)-490-0007 (toll free)

Privacy policy updates

SKLSI may update this Policy from time to time. Please check this Policy periodically for changes. If we make any changes, the updated Policy will be posted with a revised effective date. We encourage you to periodically review this page for the latest information on our privacy practices.

Last Updated: 11/20/2023 (v5)

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