Privacy Policy

Issued: May 24, 2021

This is the Privacy Policy for the Centessa Group websites (which we refer to in this Privacy Policy as the “Site” or “Sites“).

1.  Who We Are and Important Information

This Site and each of our Centessa Group Sites listed at Appendix 1 of this Policy are owned and operated by Centessa Pharmaceuticals plc (“Company“, “we“, “us” or “our“) and its group of companies (“Centessa Group“). Each company in the Centessa Group is committed to protecting and respecting your privacy.

For the purposes of the data covered by this Privacy Policy, we and the relevant Group company of the Site you are accessing, are the controller. We shall process all personal data covered by this Policy in compliance with relevant data protection laws, including the GDPR and any applicable privacy laws within the jurisdictions in which we operate.

For any questions in respect of this Privacy Policy, you can contact us at info@centessa.com.

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we will collect, use, store and transfer your personal data when you visit our Site, and any data you may provide when you use our Site, sign up for alerts or newsletters, contact us with a question or request for help. This Privacy Policy supplements other privacy notices which we may bring to your attention and is not intended to override them.

2.  The Data We Collect About You

Personal Information” is information which identifies you personally or by which your identity can be ascertained. This may include your name, address, e-mail address, and other contact details.

Types of personal data we collect

We may collect, use, store and transfer different kinds of personal data about you, including:

(a)  Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.

(b)  Contact Data includes contact address, email address and telephone numbers.

(c)  Technical Data includes internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location data, browser plug-in types and versions, operating system and platform, and other technology or information stored on the devices you allow us access to when you visit the Site, such as friends lists or other digital content.

(d)  Profile Data includes your username and password, your interests, preferences, feedback and survey responses.

(e)  Usage Data includes information about how you use our websites.

(f)  Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, as well as data you provide to us via social media.

Aggregated Data

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data where the aggregated data cannot be linked to you specifically. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.

Consequences of not providing personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you (where the personal data is necessary for the performance of that contract), and you refuse to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3.  How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

i)  Direct interactions. You may give us your Identity Data and Contact Data by filling in forms, by email or otherwise.

ii)  Automated technologies or interactions. As you interact with us via our websites or applications, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please refer to our main website, where you can access the Cookie Consent banner for more details.

4.  How We Use Your Personal Data

You can see a full list of the types of data we process, the purpose for which we process it and the lawful basis on which it is processed at the end of this policy.

Consent

Generally, we do not rely on consent as a basis for processing your personal data, although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw such consent to marketing at any time by contacting us. See below for further detail on marketing.

Marketing

Where permitted in our legitimate interest (or with your prior consent where required by law), we will use your personal information for marketing analysis and to provide you with promotional update communications by email. Please refer to the ‘Your rights’ section of this policy if you wish to change your direct marketing and contact preferences.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly. For more information about the cookies we use, please refer to our Cookie Policy, or the Cookie Consent banner for more details.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you first and we will explain the lawful basis which allows us to do so.

5.  Disclosures of Your Personal Data

We may share your personal data with our third party service providers, agents, subcontractors and other associated organisations, our group companies and affiliates (as described below) in order to complete tasks. When using third party service providers, they are required to respect the security of your personal data and to treat it in accordance with the law.

We may pass your personal data to the following entities:

(a)  companies and organisations that assist us in providing the Sites;

(b)  anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the Sites;

(c)  any third party as a result of any restructure, sale or acquisition of our group or any Affiliates, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us; and

(d)  regulatory and law enforcement authorities, whether they are outside or inside of the United Kingdom, where the law allows or requires us to do so.

6.  International Transfers

Some of our external third parties (described in paragraph 5 above) and certain members of the Centessa Group are based outside the UK and the EU. Their processing of your personal data will necessarily involve an international transfer of your data.

Where your information is transferred outside the EEA, we will take steps to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this Policy.

We may transfer your personal information outside the EEA:

  • Where we are legally required to do so.
  • In order to facilitate the operation of our Group, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

Where we transfer your personal information to a jurisdiction not subject to a legal adequacy finding, we will take steps to ensure an appropriate legal adequacy safeguard is in place which usually means, use of specific approved contracts that rely upon standard contractual clauses (SCC)s for the protection of personal data.

For further information on transfers outside of the EEA and/or specific safeguard methods adopted, please contact: info@centessa.com.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, damaged or accessed in an unauthorised or unlawful way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Depending on the nature of the risks presented by the proposed processing of your personal data, we will have in place the following appropriate security measures:

(a)  organisational measures (including but not limited to staff training and policy development);

(b)  technical measures (including but not limited to physical protection of data, pseudonymisation and encryption); and

(c)  securing ongoing availability, integrity and accessibility (including but not limited to ensuring appropriate back-ups of personal data are held).

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. If you want to know more about our security practice, please contact us at info@centessa.com.

8.  Storage Limitation

How long will you use my personal data for?

Data protection law does not generally dictate how long any personal data is required to be kept. To determine the appropriate retention period for personal data, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised 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, regulatory, tax, accounting or other requirements. If you would like more details about retention periods, please contact us at info@centessa.com.

If we determine that we no longer need your personal data to fulfil the purposes we collected it for, we will either erase (delete) it or anonymise it. Here are some typical factors which we usually consider when determining how long we need to retain your personal data:

(a)  in the event of a complaint;

(b)  if we reasonably believe there is a prospect of litigation in respect to our relationship with you or if we consider that we need to keep information to defend possible future legal claims;

(c)  to comply with any applicable legal and/or regulatory requirements with respect to certain types of personal data (e.g. information needed for audit purposes etc); or

(d)  in accordance with relevant industry standards or guidelines.

Please bear in mind that the right to deletion/erasure of your personal data is not absolute which means that in some circumstances, whilst you can ask us to delete your data, we may have lawful grounds to retain it: see Your Legal Rights paragraph below for further information.

9.  Your Legal Rights

Under certain circumstances, you have rights under the data protection laws in relation to your personal data:

(a)  Right to be informed. This enables you to be informed at all times about who we are and the purposes for processing your personal data. Request access to your personal data.

(b)  Request access to your personal data. (commonly known as a ’data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

(c)  Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(d)  Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. If a valid erasure request is received, we will take steps to ensure erasure. You will be informed after your personal data has been erased.

(e)  Object to the processing of your personal data. This applies where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your individual rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(f)  Right to stop direct marketing. Where we are processing your personal data for direct marketing purposes, you have the right to notify us in writing requesting that we cease or do not begin processing your personal data for direct marketing purposes.

(g)  Rights in relation to automated decision making. This applies if the decision is made solely by automated means (without human involvement). You will be notified when decisions are made solely on an automated basis.

(h)  Request restriction/stop of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (1) If you want us to establish the data’s accuracy; (2) Where our use of the data is unlawful but you do not want us to erase it; (3) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; (4)  You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

(i)  Request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format (if feasible). Note that this right only applies to automated information which you initially provided consent for us to use or where you provided the information to us to perform a contract with you.

(j)  Right to withdraw consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You may withdraw consent at any time where we are relying on consent to process your personal data by contacting us through [insert contact details]. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

10.  Right to complain/seek compensation – please see ‘Lodging a complaint with a data protection authority’ section below.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required:

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 manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer if your request is particularly complex or you have made a number of requests, also if more time is required to consult with a third party or other data controller (if needed) before we can reply to your request; In this case, we will notify you and keep you updated.

Lodging a complaint with a data protection authority

You can also lodge a complaint with the applicable data protection authority. For the UK this is the Information Commissioner’s Office (www.ico.org.uk). A detailed list is available here: https://edpb.europa.eu/about-edpb/board/members_en

We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority, so please feel free to contact us in the first instance.

APPENDIX 1 – CENTESSA GROUP WEBSITES AND DATA CONTROLLERS

The specific data controller for you will depend on the Centessa group website that you are accessing. These are as follows:

LocationData controllerLocationData Controller
UKCentessa Pharmaceuticals plc

https://www.centessa.com/

UKApcinteX Limited

http://www.apcintex.com/

UKCapella Bioscience Ltd

http://www.capellabioscience.com/

UKJanpix Limited

https://www.janpixbio.com/

UKMorphogen-IX Limited

https://www.morphogen-ix.com/

UKOrexia Therapeutics Limited

https://www.orexiatherapeutics.com/

UKZ Factor Limited

http://www.zfactor.co.uk/

USPalladio Biosciences Inc

https://palladiobio.com/

APPENDIX 2 – TABLE OF PROCESSING ACTIVITIES

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the lawful 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 on more than one lawful ground depending on the specific purpose for which we are using your data.

PURPOSE / ACTIVITYTYPE OF DATALAWFUL BASIS FOR PROCESSING
To register you as a new user of the Sites(a)  Identity Data

(b)  Contact Data

(a)  Performance of a contract with you
To manage our relationship with you which may include:

(a)  Asking you to leave a review or

(b)  responding to any enquiries or communications from you

(a)  Identity Data

(b)  Contact Data

(c)  Profile Data

(d)  Marketing and
Communications Data

(a)  Performance of a contract with you

(b)  Necessary for our legitimate interests (to keep our records updated and to study how customers use our Sites)

To enable you to complete a feedback request or survey(a)  Identity Data

(b)  Contact Data

(c)  Profile Data

(d)  Usage Data

(e)  Marketing and Communications Data

(a)  Necessary for our legitimate interests (to develop our business)
To administer and protect our business, our Site and applications including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data(a)  Identity Data

(b)  Contact Data

(c)  Technical Data

(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 reorganisation or group restructuring exercise)

(b)  Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you(a)  Identity Data

(b)  Contact Data

(c)  Profile Data

(d)  Usage Data

(e)  Marketing and Communications Data

(f)  Technical Data

(a)  Necessary for our legitimate interests (to study how customers use our Sites, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, marketing, customer relationships and experiences(a)  Technical Data

(b)  Usage Data

(a)  Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to form our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you based on your interactions with us.(a)  Identity Data

(b)  Contact Data

(c)  Technical Data

(d)  Usage Data

(e)  Profile Data

(f)  Marketing and Communications Data

(a)  Necessary for our legitimate interests (to develop our products and grow our business)

Please contact us if you need details about the specific lawful ground we are relying on to process your personal data where more than one ground has been set out in the table below.

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