What Personal Information We Collect About You
In general, we will not collect any personal information about you unless you provide it to us voluntarily. You are not required to provide any personal information as a condition of visiting our website. However, we may obtain information about you from public or third party sources. For example, if you are a healthcare professional, we may collect information about you from public sources for research and collaboration purposes and to verify professional information.
You may provide personal information to us through the “Contact Us” page of our website or by communicating with us through other means. For example, you may inquire about enrolling in clinical trials we are or will be sponsoring, or if you apply for an open position in our company. You may contact us through interacting with our employees or contractors.
The types of personal information we may collect and process include:
- General information, such as names, mailing or email addresses, phone numbers, date of birth, photographs and copies of government-issued IDs
- Professional information, such as job titles, education and professional qualifications, professional networks, and programs and activities in which you participate
- Health and genetic information, such as diseases or conditions you may have, medical history and records, and diagnostic testing results
- Digital information, such as any digital identifiers (e.g., usernames, Twitter handles), IP addresses and data transmitted via cookies.
For health and genetic information, we generally do not collect that information directly and instead receive it from third parties such as our clinical trial sites. Our practice is for that information to be pseudonymized – in other words, replacing any personally identifiable information, including the name of the clinical trial participant, with codes to render the individual difficult to identify. While pseudonymization protects the identity of the individual and we do not intend to know the identity of the individual, it is still possible that the identity of the individual may be learned from the data that we collect and/or other data that third parties may have.
Why We Collect and Process Personal Information
We only collect and process your personal information for our legitimate business purposes and if permitted by applicable laws, which may vary depending on where you live and where we operate. These laws include, for example, the General Data Protection Regulation of the European Union (the GDPR), which applies to the collection and processing of personal data of European citizens and residents. For personal information subject to the GDPR, we will not collect or process that information unless we have a lawful basis to do so under the GDPR.
The purposes of processing personal information may include:
- Clinical trials: for example, screening and enrolling participants in our clinical trials, conducting our clinical trials, obtaining and analyzing results from our clinical trials
- Regulatory compliance: for example, reporting any issues relating to drug safety to the applicable regulatory authorities and maintaining records of our clinical trials in accordance with applicable laws
- Collaborations: for example, identifying and engaging with key opinion leaders and healthcare professionals, responding to and pursuing business development opportunities
- Recruitment and employment: for example, responding to applications from candidates for open positions, conducting background checks, processing payroll and benefits for employees and contractors
- Marketing: for example, inviting individuals to our and industry events, conducting outreach to investors and potential collaborators
- Website and operations: for example, protecting the security of our personnel and assets, improving our website, including its functionality, and monitoring web traffic
- Any other purposes that is relevant to the relationship between IVERIC bio and you
How We Process and Share Your Personal Information
We process and disclose personal information when reasonably necessary to pursue our legitimate business objectives and when required by law. If we are legally required to disclose any personal information, we will take reasonable steps to protect that personal information and limit disclosure to what is required.
We use third parties to help us collect and process personal information on our behalf. For example, we have engaged clinical trial sites and contract research organizations to help us conduct and oversee our clinical trials. We have written agreements in place with third party processors that include provisions to protect the personal information that they process on our behalf. We take other appropriate measures, such as routine audits, to ensure that adequate security and technical measures are in place at our processors to protect your personal information from unauthorized access, use or disclosure. However, please keep in mind that these measures are not guaranteed to prevent all unauthorized access, use or disclosure.
We may transfer your personal information across borders, including into or out of the United States, where we are headquartered. Please note the laws protecting the use of personal information in the United States and other countries may be different from your home country’s laws. We endeavor to take reasonable steps to have adequate safeguards to protect your personal information when it is transferred across borders.
We aim to retain your personal information for no longer than as needed for the specific business purpose(s) for which it is collected. However, we may be required by law to retain the information longer.
We may also disclose personal information to our affiliates, who are subject to the same privacy provisions as us, and to our professional advisers, contractors and agents, who are subject to stringent confidentiality obligations.
We may need to transfer your personal information in connection with a corporate reorganization, or acquisition or combination with another entity.
Security Measures To Protect Your Personal Information
We have implemented reasonable and industry-standard security measures to protect our physical and electronic systems from unauthorized access, use, alteration and disclosure of information under our control. We routinely test those measures and update them as needed to protect our information security systems.
However, even with those measures, we cannot guarantee that unauthorized access, use, alteration or disclosure of personal information will not occur. You should understand that your use of our website is subject to the same limitation and information submitted through our website may be compromised. In particular, we encourage you not to submit any sensitive personal information, such as health information or financial information, through our website.
Your Rights to Your Personal Information
Under applicable privacy laws (such as the GDPR), you may have a right to request, free of charge, a copy of information about you that we have collected and processed or the terms of any consent that you provided us to process your personal information. You may also have the right to correct, delete or transfer such information, or have us stop processing that information. We will use reasonable efforts to comply with your request. Keep in mind that your rights may be subject to legal and regulatory obligations imposed on us.
See the “Contact Us” section below about how to exercise your rights. Your request will be forwarded to the most appropriate IVERIC bio team member. Depending on the nature of the request, you may be required to provide additional information (including as required to verify your identity).
Information for Clinical Trial Participants
As a biopharmaceutical company, one of our principal activities is sponsoring and conducting clinical trials of our product candidates. The purposes of these clinical trials are to evaluate those product candidates in humans to determine whether those product candidates are safe and effective treatments for the intended diseases. Clinical trials are subject to stringent oversight by regulatory authorities such as the U.S. Food and Drug Administration (FDA) and the European Medicines Agency (EMA).
We collect and process the personal information of prospective and enrolled participants in our clinical trials. In our clinical trials, clinical trial sites collect the participant’s name, medical history and other relevant personal information from individual clinical trial participants and then will pseudonymize any personally identifiable information into codes that make it difficult to identify the individual to whom such information belongs. This key coded data may be associated with information relating to physical health, ethnicity, gender, and other medical information. Coded study data will only be used for research purposes, including follow-up regarding the safety and effectiveness of the study medication. Only authorized members of the study investigator’s staff, our personnel or the third parties that help us conduct the study will have access to this data. We may transfer the coded study data outside your country in order to further analyze the data to submit the data to regulatory authorities.
We will not have access to the names or contact details of clinical trial participants, and we do not seek to identify our clinical trial participants. You should contact the clinical trial site and the clinical trial investigators to learn more about how your information is processed by them.
We may also share information collected during the study with outside scientists and other collaborators for further scientific research in the interest of public health. We will not provide information about your identity to those scientists and collaborators.
We are required by law to retain certain information collected during clinical trials for periods of time following conclusion of the trials. We may need to share this information with regulatory authorities in accordance with applicable laws.
Information for Current and Prospective Employees and Contractors
We process personal information to identify potential and actual applicants and to evaluate job applications. The information processed may include information such as your name, your job title, education information, professional qualifications, work experience, publications and scientific activities, professional networks, and programs and activities in which you participate.
In the course of considering an application and upon starting work with us, we may process other personal information for human resources purposes, such as government-issued ID numbers, tax status, bank account details, details of disability/workplace accessibility needs, personal and family background information, travel and expenses information, emergency contact details, and benefits related information
Our website is not intended or designed for children under the age of 13. Without the prior authorization of his or her parent or legal guardian, we do not collect personal information from any individual whom we know to be under the age of 18.
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IVERIC bio, Inc.
One Penn Plaza, Suite 3520
New York, NY 10119
Attn: Legal Department
If you are a citizen or resident of the European Union, in lieu of contacting us, you may contact our GDPR Article 27 Representative, DPR Group. For more information, please click here.
Adopted June 2019