Privacy Policy

Shield Therapeutics Inc is committed to protecting and respecting your privacy.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. We may change this policy from time to time. Please check back frequently to see any updates or changes. This policy is effective as of April 26, 2021 and will be frequently reviewed.

This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed. For the purposes of data protection legislation, Shield Therapeutics is the data controller.

The Interactions this Privacy Policy Covers

Except as otherwise provided in this Privacy Policy, this Privacy Policy applies to personal information (as defined below) that we collect or process in course of our relationship with (i) all our customers, vendors and suppliers, as well as individuals related to such customers, vendors and suppliers and (ii) visitors to and users of websites we own and control ((i) and (ii) collectively, “you” or “your“), including but not limited to: Accrufer.com; AccruferHCP.com; shieldtherapeutics.com, including any subdomains thereof, related mobile applications and electronic communications (the “Site“) and through other online or offline business-related interactions with you. This Privacy Policy applies to all personal information you provide to us, or that we obtain from you through the Site. By providing us your personal information, or by using the Site, you consent to and accept this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, please do not use the Site or provide us with your personal information.

Except as otherwise provided in this Privacy Policy, personal information is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you, other than information which is generally excluded from the definition of “personal information” under applicable law (such as protected health information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA)) (“personal information”). Personal information does not include information which cannot reasonably be linked, directly or indirectly, with you, including, for example, information which has been aggregated so that it can no longer reasonably be linked to any particular individuals. Personal information also does not include information which is generally excluded from the definition of “personal information” under applicable law.

Third-Party Websites

The Site may contain links to websites owned and operated by third parties. Please note that we do not control such third-party websites, the content of these sites, any products or services that may be offered through these sites, or any other use of the linked sites. The links to such websites do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. These other websites may send their own cookies to visitors, collect data or solicit personal information, and the privacy policies of these other sites may be significantly different from this Privacy Policy. Your access to and use of such websites is governed by the terms of use and policies of those sites, and shall be at your own risk. We are not responsible for the privacy practices of these other sites and cannot guarantee the security of any information collected by any linked or other third-party website. Your use of those websites is governed by any policies existing on or applicable to those websites. We encourage you to review the privacy policy of any company or website before submitting your personal information.

We are active on social media pages and we may integrate social media widgets or features on the Site. These social media companies may recognize you and collect information about your visit to the Site, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

What Personal Information We Collect and How We Collect It

(a) Information We Collect

Certain features on the Site enable you to provide us with certain personal information that we may use to contact or identify you. This information may include, but is not limited to:

  • Identifiers such as first and last name; email address, phone number, mailing address, IP address, and online identifiers;
  • Protected classification characteristics under state or federal (United States) law such as: race, sex, age, marital status, sexual orientation, insurance information, and prescription information;
  • Biometric information such as behavioral characteristics, activity and patterns used to extract health data;
  • Preferences (including emotional or romantic orientation);
  • Financial information;
  • Certain medical information to comply with pharmacovigilance, reporting to regulatory authorities, and for other legal or regulatory requirements.
  • Company name and position or title;
  • Other commercial information (e.g., records of products purchased from us);
  • Internet activity (e.g., information on your interactions with the Site);
  • Geolocation data;
  • Demographic information;
  • Professional or employment related information such as previous employment history;
  • Education information;
  • Information that we may collect from you offline in connection with business-related interactions with you, such as if you provide information to us at an industry event, business meeting, or contact us by telephone; and
  • Any other form or category of personal information which you directly submit to us in any manner, including but not limited to in emails or survey responses.

(b) How We Collect Information

We may collect the categories of personal information listed above from the following categories of sources:

(i) From You

We collect personal information from you in the following ways:

  • Directly from you when you:
    • Inquire about our services and offerings;
    • Contact us through the “Contact Us” link on the Site;
    • Create an account on the Site;
    • Sign up for email updates;
    • Participate in a survey, promotion or event;
    • Enter into a contract with us; or
    • Otherwise submit personal information or materials or content containing personal information to us, including but not limited to, via a submission on the Site or via an email or phone call to us.
  • Indirectly from you:
    • By observing your actions on the Site;
    • When you have opted into marketing via third-party programs;
    • Via social media platforms;
    • From your employer, principal, authorized representative or agent enters into a contract with us; or
    • When you are referred to us through a marketing promotion.

If you contact us through electronic communication, including by email, we typically retain the email in our file servers and collect any contact information you provide so that we can reply to you. Your email also contains metafiles that may contain IP addresses, domain names, and other standard file information and this information may be retained electronically on our servers or in routine back-up files.

If you browse the Site, regardless of whether you create a user account, or otherwise interact with the Site, we log your IP address (the internet address of your computer) to tell us which parts of the Site you visit and how long you spend there. We may also track the state and/or country you are accessing the internet from, the date and time you visited and the type of computer, operating system and web browser you are using. We may also obtain additional information about you from other sources, including from our suppliers, service providers, public databases, social media and other third parties. For instance, we may use information obtained from third parties to confirm your contact or financial information, to verify licenses or obtain other information.

(ii) Cookies

We also use “cookies,” pixels, web beacons, and other technologies to receive and store certain information when you interact with the Site. We also allow third parties to use cookies on the Site as described in our cookie policy. You may refuse the use of cookies by selecting the appropriate settings on your browser; however please note that if you do this you may not be able to use the full functionality of the Site.

(iii) Analytics

We utilize third party companies and analytics to help us market, sell, and provide information about our products and services; and we provide your personal information to these third party companies to assist us in conducting business with you. We may use web analytics tools provided by service providers, including, but not limited to, Google Analytics, which is a third party service that transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We may use reports provided by Google Analytics or other similar service providers, to help us understand the Site’s traffic, and web page usage. For more information concerning Google Analytics and how it collects and processes data please see “How Google Uses Data When You Use Our Partners Web Sites or Apps” located at https://policies.google.com/technologies/partner-sites. We may use the information provided by these tools to improve our services and our online advertisements. These tools place session and persistent cookies in your browser to identify you as a unique user the next time you visit the Site. Each cookie cannot be used by anyone other than the service provider (e.g. Google Analytics).

(iv) Other Sources

To the extent permitted by applicable data protection laws, we may also receive personal information or draw inferences about you from other sources. These may include commercially available sources, such as public databases, data aggregators, advertising networks, internet service providers, data analytics providers, social networks, and data brokers. If applicable data protection law requires it, we will obtain your consent before using your personal information for our business purposes.

Purposes for Use of Personal Information

We may process, use, sell or disclose the personal information we collect for one or more of the following business purposes:

  • Respond to your questions and requests;
  • Improve customer service;
  • Send you email updates;
  • Create, maintain, customize, and secure your account with us;
  • Provide the products and services you request;
  • Identify your product and services preferences;
  • Promoting our business and products, including but not limited to providing testimonials;
  • Personalize your experience on the Site and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads;
  • Provide information concerning products and services you have purchased and products and services that may be of interest to you;
  • Help maintain the safety, security, and integrity of the Site, products and services, databases and other technology assets, and business;
  • Engage in other activities in the normal course of running a biopharmaceutical company;
  • Protecting rights and interests of the Company; and
  • To fulfill regulatory and legal requirements.

We may also use your personal information for any other purpose with your consent.

How We Share Personal Information

We may disclose your personal information to a third party for a business purpose, or sell your personal information, subject to applicable rights you may have by operation of applicable law.

We may share your personal information with the following categories of third parties:

  • Service providers who have been retained to perform services on our behalf to help with proposed or actual business activities, including without limitation, contractors, insurers, physicians, medical providers, email and SMS vendors, hosting and development companies, fulfillment companies, common carriers and payment processors, to help us market our products and services, process orders, deliver products, perform market research, promotions management and otherwise assist us in running our business.
  • Data aggregators and data analysis firms.
  • Other Parties: We may share information with third parties such as third party marketing companies, for business purposes subject to applicable data protection laws.
  • Aggregate Information: We may share aggregate information, such as demographic and usage statistics, with other organizations.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

We may share your personal information with our subsidiaries and affiliates, to enforce or apply our terms of use, terms of sale or other agreements, including for billing and collection purposes, to otherwise defend the rights of the Company or its affiliates or business partners and to protect the rights, property or personal safety of our employees, agents, affiliates, business partners, customers or Site users.

We may also disclose information about you (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation or arbitration; (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with the prevention of or the investigation or prosecution into suspected or actual illegal activity; or (v) if in good faith we believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed by third party forensic investigators and other technology professionals for security purposes – e.g., to detect unauthorized activity on the Site. In such cases, server log data containing IP addresses may also be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing, of all or any portion of the Company or of any of our assets (including should we become insolvent, enter into receivership or any similar event occur). Should such an event take place, we will endeavor to direct the proposed or actual transferee and its advisors to use personal information in a manner that is consistent with this Privacy Policy.

We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing, of all or any portion of the Company or of any of our assets (including should we become insolvent, enter into receivership or any similar event occur). Should such an event take place, we will endeavor to direct the proposed or actual transferee and its advisors to use personal information in a manner that is consistent with this Privacy Policy.

We may take personal information and aggregate data so that it is no longer identifiable. We may use this information to enhance the features of the Site and services. We may also sell or license this aggregated information to third parties or publish the information. We will take reasonable precautions to ensure that such aggregated information does not contain any confidential or otherwise identifiable data that could be used to identify its source.

How We Secure Personal Information

We maintain commercially reasonable procedures and technology designed to prevent the unauthorized access of your information that you provide to us. We maintain reasonable technical, administrative and organizational security measures in place to protect the loss, misuse or alteration of information under our control. However, we cannot guarantee that unauthorized third parties will never be able to defeat those security measures.

If you believe your information has been accessed in an unauthorized manner, please contact us immediately using the details provided below.

How We Retain Personal Information

Except as applicable laws require and as otherwise provided in this Privacy Policy, we will retain the personal information we receive as described in this Privacy Policy for as long as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with all applicable laws and in accordance with our routine information storage policies.

Changes and Updates to this Policy

If you choose to do business with us or visit the Site, your visit and any disputes over personal information or privacy are subject to this Privacy Policy. The Company reserves the right to change this Privacy Policy at any time without notice except as otherwise provided in this Privacy Policy. Please check back periodically to see if our Privacy Policy has been updated. Your continued engagement as a vendor, supplier, or customer of the Company or as a user of the Site constitutes your agreement to the terms of this Privacy Policy and any future versions of this Privacy Policy.

Governing Law

Unless otherwise required by applicable law, this Privacy Policy, and the Company’s collection and use of personal information, shall be governed and interpreted in accordance with the laws of the United States and the State of Delaware. 

Children

We do not knowingly collect personal information from children under the age of 16 through the Site. Children are not encouraged to use the Site and we request that children under the age of 16 not submit any personal information to the Site. Since information regarding children under the age of 16 is not collected through the Site, we do not sell the personal information of individuals we actually know are less than 16 years of age. 

Contact Us

If you have any questions or concerns regarding this Privacy Policy or our privacy practices, we encourage you to contact us by:

However, if you are a Data Subject and feel we have not resolved a privacy concern related to personal information processed or transferred by the Company, you have the right to submit a complaint to a supervisory authority.