Asgard Therapeutics AB – Privacy Policy
Information on how we process your personal data
1. Introduction
This Privacy Policy (the “Policy”) describes how Asgard Therapeutics AB, reg. no. 559184-0136, with address at Medicon Village, 223 81 Lund, Sweden (“Asgard”, “we”, “us” or “our”), processes your personal data when you visit and use our website or come into contact with us because of our business – usually because you represent a supplier or a partner of ours, apply for an employment with us, is a consultant or a part of our board or special advisory board.
We are responsible for the processing of your personal data as described in the Policy in the capacity of data controller. If you would like to know more about our processing of your personal data, you are welcome to contact us, e.g. via the address above or via our email address: info@asgardthx.com.
It is important to us that you feel comfortable with how we process your personal data, and we therefore ask you to read through this Policy, which we may update from time to time. If we make changes to the Policy, the new version will apply from the time it is published on our website. At the top of the page, you can see when the Policy was last changed.
2. Information on how we process your personal data
The personal data we process relating to you is mainly collected from you when you visit and use our website or when we come into contact with you – e.g. via email, telephone or personal meetings, conventions or similar occasions. We may also collect your personal data from a third party, usually from the company or organization you represent.
3. How we process your personal data
3.1 Introduction
We only process your personal data to the extent permitted in accordance with applicable data protection legislation. This means inter alia that we need to have a legal basis for the purposes for our processing of your personal data, which in our context generally means one of the following legal bases.
Performance of a contract – the processing is necessary in order for us to provide you with our services or otherwise perform a contract between us (this applies if you conduct your business in a sole proprietorship), or to take steps at your request prior to entering into a contract.
If you are acting on behalf of someone else, e.g. in the capacity of representative of a company (which usually is the case), our processing is carried out with reference to our legitimate interest balanced against your interests or fundamental rights or freedoms, where our legitimate interest is to conclude and perform the contract with the company you represent.
Performance of legal obligations – the processing is necessary in order to fulfil our legal obligations according to law or other statutes that we are subject to, or if we are subject to orders or decisions by courts or authorities, which require us to process your personal data.
Legitimate interests – the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, provided that they are not overridden by your interests or fundamental rights or freedoms (in which case the processing would not be allowed).
Consent – the processing is carried out with your prior consent, where we inter alia are responsible for clearly informing you of what processing you consent to and your right to withdraw your consent in relation to our continued processing.
Below, we explain more about the categories of personal data we process, for what purposes we process them and what legal bases we rely on when processing your personal data, including for how long we store your personal data and who we share your personal data with.
3.2 To create potential academic cooperations or business relationships
Purposes of the processing
Contact and communication with you for the purposes of creating an academic cooperation or business relationship with you or the company or organization you represent.
This includes, among other things, communication via email regarding our business and current activities (see also Section 3.6 below).
Categories of personal data
The personal data we process consist of:
– First and last name
– Contact details such as email address, telephone number, location and business address
– Professional title and information regarding the company or organization you represent
– Information that you otherwise provide us in our communications with you.
Legal basis: Legitimate interests, where our legitimate interest is to create an academic cooperation or a business relationship with you or the company or organization you represent.
Storage period: We store your personal data for a period of six months after the data was collected. If an academic cooperation or a business relationship is established between us and you or the company or organization you represent during this time, we will however continue to process your personal data in accordance with Section 3.3-3.5 below.
Sharing of personal data: We will share your personal data with our suppliers such as e-mail providers.
3.3 To maintain and develop existing academic or business relationships
Purposes of the processing
Contact and communication with you in your capacity as, or representative for, one of our existing partners, cooperation organizations such as universities or other business contacts, in order to maintain and develop our relationship with you or the company or organization you represent.
This includes, among other things, regular administration and communication regarding our agreements and communication via email about our business, cooperation and our current activities (see also Sections 3.4 and 3.5 below).
Categories of personal data
– First and last name
– Contact details such as email address, telephone number, location and business address
– Professional title and information regarding the company or organization you represent
– Information that you otherwise provide to us in our communication with you.
Legal basis: Legitimate interest, where our legitimate interest is to maintain and develop our business relationship with you or the company or organization you represent.
Storage period: We process and store your personal data for as long as we have a business relationship with you or the company or organization you represent, but no longer than two years after the last time we were in contact in the capacity of our relationship
We may however need to store your personal data for a longer time for other purposes, e.g. if we need to take measures in order to establish, exercise or defend legal claims. We may also need to store your personal data for a longer time in order to fulfil our legal obligations relating to e.g. book keeping. Accounting information is as a starting point stored for seven years after the end of the current financial year according to the Swedish Accounting Act (1999:1078).
Sharing of personal data: We will share your personal data with our suppliers.
3.4 To administer the conclusion and performance of contracts
Purposes of the processing
Administration and communication in order to conclude or perform a contract between us and you or the company or organization you represent.
This includes, among other things, invoicing and customary contract management, as well as following up and documentation of contract related matters.
Categories of personal data
The personal data we process consist of:
– First and last name
– Contact details such as email address, telephone number, location and business address
– Professional title and information regarding the company or organization you represent
– Information that you provide to us in contract related matters with you or the company you represent, e.g. questions and feedback.
Legal basis: The processing is necessary to conclude and perform a contract with you or the company or organization that you represent. If you are acting on behalf of someone else, e.g. in the capacity of representative of a customer, partner or supplier to us, our processing is carried out based on our legitimate interests, where our legitimate interest is to conclude as well as perform the agreement with the company or organization you represent.
Storage period: We process and store your personal data for as long as we have a business relationship with you or the company or organization you represent, but no longer than two years after the last time we were in contact in the capacity of our business relationship.
We may however need to store your personal data for a longer time for other purposes, e.g. if we need to take measures in order to establish, exercise or defend legal claims. We may also need to store your personal data for a longer time in order to fulfil our legal obligations, e.g. relating to book keeping according to the Swedish Accounting Act (see further Section 3.6 below).
Sharing of personal data: We will share your personal data with our suppliers and advisors.
3.5 To manage relations with our board members, consultants and advisors
Purposes of the processing
Administer relations and fulfil obligations regarding salary or other renumeration for your services as a consultant or advisor in our advisory board.
Categories of personal data
The personal data we process consist of:
– Email address
– First and last name
– Position / professional title
– Salary/compensation
– Travel and expense compensation
– Bank account number
Legal basis: Performance of the contract between us. If you provide your services via a company our legal basis is our legitimate interest, where our legitimate interest is to maintain and develop our business relationship with you or the company or organization you represent.
Storage period: The personal data is stored for the time needed for us to be able to fulfil our obligations under your contract but as a starting point for one year after your appointment has ended.
In addition, we need to store some accounting information due to Swedish law. Accounting information is as a starting point stored for seven years after the end of the current financial year according to the Swedish Accounting Act (1999:1078).
The personal data can also be stored under e.g. the time necessary to establish, assert or defend legal claims (normally no longer than ten years from the date of registration of the data).
Sharing of personal data: If we use a recruitment consultant we will share your personal data with our suppliers of marketing services.
3.6 To recruit new employees
Purposes of the processing
To facilitate and follow up on job applications.
Categories of personal data
The personal data we process consist of:
– Email address
– First and last name
– Telephone number (if provided)
– CV
– Personal data set out in cover letter
Legal basis: The processing is carried out based on our legitimate interests, where our legitimate interest is facilitating and following up on job applications. In case you wish not to apply for a specific position or wish to enable us to keep your application for future job openings, such processing is based on your consent.
Storage period: Personal data on job applicants is kept for the term of the recruitment period for an additional period of two years and three months in order for us to defend any legal.
Sharing of personal data: If we use a recruitment consultant, we will share your personal data with such supplier.
3.7 To update and maintain our share register
Purposes of the processing
To administer and fulfil legal requirements to keep and update our share register.
Categories of personal data
The personal data we process consist of:
– Email address
– First and last name
Legal basis: Fulfilment of legal obligations under the Swedish Companies act.
Storage period: For as long as you are a shareholder and for as long as the information is retained during the time it is needed for us to fulfil our commitments and obligations.
Sharing of personal data: We will share your personal data with our suppliers.
3.8 Personal data related to you if you contact us through our website
Purposes of the processing
To respond to your query or your request for information.
Categories of personal data
The personal data we process consist of:
– Email address
– First and last name
– Any other personal data you submit to us in the contact form.
Legal basis: The processing is carried out based on our legitimate interests, where our legitimate interest is to respond to your query or your request for information.
Storage period: The information is retained during the time it is needed for us to respond to you and manage your matter.
Sharing of personal data: We will share your personal data with our suppliers.
3.9 To fulfil legal obligations or to establish, exercise or defend legal claims
We may process your personal data in order to fulfil our legal obligations according to law or other statutes that we are subject to, or if we are subject to orders or decisions by courts or authorities, which require us to process your personal data.
We may also process your personal data so that you, or the company or organization you represent, we or any relevant third party can establish, exercise or defend its legal claims, e.g. in connection with an ongoing dispute.
4 Security measures
We have taken measures to ensure that your personal data is handled in a safe way. For example, access to systems where personal data is stored is limited to our employees and service providers who require it in the course of their duties. Such parties are informed of the importance of maintaining security and confidentiality in relation to the personal data we process. We maintain appropriate safeguards and security standards to protect your personal data against unauthorized access, disclosure or misuse. We also monitor our systems to discover vulnerabilities. In addition, data processing agreements have been entered into with our suppliers of systems and services (see further Sections 5 and 6 below).
5. How we share your personal data
Access to your personal data is limited to recipients who require such access for the purposes described in Section 3 above or as otherwise stated below. Your personal data will therefore be shared with the following categories of third party recipients:
a) Service providers: We use third party service providers to manage parts of our business operations. We will share personal data with such third parties in order for them to supply us with services, e.g. IT services or other administrative functions or provide services as sub-contractors in connection with our own services. When we use such service providers, we enter into data processing agreements and take other suitable measures to ensure that your personal data is processed in line with this Policy.
b) Our partners: We will from time to time cooperate with external parties in order to improve our services and business. Such parties either process your personal data as data controllers according to their own terms and policies for handling personal data, or as our data processors according to our instructions. In the latter case, we enter into data processing agreements and take other suitable measures to ensure that your personal data is processed in line with this Policy.
c) Sale or transfer of business or assets: We will share your personal data with a buyer/investor or prospective buyer/investor in the event of a sale, assignment or other transfer of all or parts of our shares, assets or operations. When such transfer occurs, we will take actions in order to ensure that the receiving party processes your personal data in accordance with this Policy. The purpose of such sharing or processing of your personal data is to allow a (potential) buyer/investor to carry out an assessment of us as a company and, where necessary, take actions and make preparations in the event a sale, assignment or other transfer should occur, where such sharing or processing of your personal data is carried out with reference to the legitimate interests of allowing such assessment, actions and preparations by the (potential) buyer/investor.
d) Public authorities: We will share your personal data with public authorities such as the Swedish Police or the Swedish Tax Agency when we are required to do so by e.g. applicable law or other legal statutes or orders or decisions by courts or authorities in order to fulfil the legal obligation specified therein.
6. Where we process your personal data
We strive to always process your personal data within the EU or EEA. However, we will transfer your personal data to service providers who, either themselves or by their sub-contractors, are located or have business activities in a country outside the EU or EEA. In such cases, we are responsible for ensuring that the transfer is made in accordance with applicable data protection legislation before it occurs, e.g. by ensuring that the country in which the recipient is located ensures an adequate level of data protection according to the European Commission, or by ensuring appropriate safeguards based on the use of standard contractual clauses that the European Commission has adopted and other appropriate measures to safeguard your rights and freedoms.
You may access a list of the countries that the European Commission has decided provide an adequate level of data protection at http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm.
You may access the European Commission’s standard contractual clauses at http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087.
7. Your rights
You have rights in relation to us and our processing of your personal data. Below, you will find information about your rights and how you can exercise them.
Please note that your rights apply to the extent that follows from applicable data protection legislation and that there may be exceptions to the rights where applicable. We also ask you to note that we may need more information from you in order to e.g. confirm your identity before proceeding with your request to exercise your rights.
To exercise your rights or request information about them we ask that you contact us, which is most easily done via email: cristiana.pires@asgardthx.com.
7.1 Right of access
You have the right to obtain a confirmation as to whether or not we process your personal data. If that is the case, you also have the right to receive copies of the personal data concerning you that we process as well as additional information about the processing, such as for what purposes the processing occurs, relevant categories of personal data and the recipients of such personal data.
7.2 Right to rectification
You have the right to, without undue delay, have incorrect personal data about you rectified. You may also have the right to have incomplete personal data completed.
7.3 Right to erasure
You have the right to obtain that we erase your personal data without undue delay in the following circumstances:
– The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
– Our processing is based on your consent and you withdraw your consent to the relevant processing;
– You object to processing that we carry out based on a legitimate interest, and your objection overrides our or another party’s legitimate interest of the processing;
– The processed personal data is unlawfully processed;
– The processed personal data has to be erased for our compliance with one or more legal obligations.
7.4 Right to restriction
You have the right to request that we restrict the processing of your personal data in the following circumstances:
– You contest the accuracy of the personal data during a period enabling us to verify the accuracy of such data;
– The processing is unlawful and you oppose erasure of the personal data and request restriction instead;
– The personal data is no longer needed for the purposes of the processing, but is necessary for you for the establishment, exercise or defense of legal claims;
– You have objected to the processing of the personal data which we carry out based on a legitimate interest, pending the verification whether your objection overrides our or another party’s legitimate interest to continue with the processing.
7.5 Right to object
You have a right to object to our processing of your personal data when it is based on our or another party’s legitimate interest. If you object, we must demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms in order to be allowed to continue with our processing.
7.6 Right to data portability
If our processing of your personal data is based on the performance of a contract with you or your consent, you have the right to receive the personal data you have provided us relating to you in an electronic format. You also have the right to have the personal data transferred from us directly to another data controller, where technically feasible.
We ask you to observe that this right to so called data portability does not cover personal data which we process manually.
7.7 Right to withdraw consent
If our processing of your personal data is based on your consent, you always have the right to withdraw your consent at any time. A withdrawal of your consent does not affect the lawfulness of the processing that took place based on the consent before your withdrawal.
8. Complaints with the supervisory authority
In Sweden, the Swedish Authority for Privacy Protection ( Integritetsskyddsmyndigheten) is the authority responsible for supervising the application of current data protection legislation. If you believe that we process your personal data in a wrongful manner, we encourage you to contact us so that we can review your concerns. However, you may file a complaint with the Swedish Authority for Privacy Protection at any time.