Privacy Notice

This Privacy Notice describes the privacy practices of ForwardTx, Inc and affiliates, (collectively, “ForwardTx”). This Privacy Notice describes how we collect, use, store and disclose (together “process”) personal data, and explains the rights and choices available to individuals.

ForwardTx may provide additional privacy notices to individuals at the time we collect their data (e.g. ICFs for clinical trial participants or recruitment disclosures for employment candidates) that describe our privacy practices in connection with specific activities and will apply to the information you provide at that time, in addition to this notice.

This Privacy Notice applies to all personal data submitted to us for use with or in connection with this site and other websites or digital portals we own or operate (the “Site”) as well as personal data collected via email, all personal data collected in connection with applications for employment, personal data we collect as necessary to deliver our products or collaborate with our research partners, and all personal data we may collect when you enter our premises. Please note this Privacy Notice does not apply to ForwardTx’s processing of employee or contractor data.

BY PROVIDING YOUR PERSONAL DATA TO FORWARDTX OR OTHERWISE USING OUR WEBSITES OR APPLICATIONS, YOU UNDERSTAND THE TERMS OF THIS PRIVACY NOTICE AND WISH TO CONTINUE TO PROVIDE YOUR PERSONAL DATA FOR THE PURPOSES DESCRIBED.

Whose Personal Data We Collect?

We collect personal data about the following types of individuals: clinical trial participants, patients, patient family members, caregivers or advocates, physicians and other health care professionals, clinical trial investigators, researchers, pharmacists, contractors, consultants, job applicants, volunteers, visitors to our offices, and other individuals who interact directly with ForwardTx or its service providers or business partners, including users of websites and mobile applications.

How We Collect Personal Data

We collect personal data:

Directly from individuals
Through our websites and mobile apps
From healthcare professionals
From contract research organizations and clinical trial investigators
From government agencies or public records
From third party service providers, data brokers or business partners
From industry and patient groups and associations
From social media or other public forums (including adverse event information or product quality complaints)
From recruiters

Types of Personal Data We Collect

The types of personal data we collect, and share depends on the nature of the relationship you have with ForwardTx and the requirements of applicable laws. The types of personal data we collect include:

Health and medical information we collect in connection with managing clinical trials, conducting research, providing patient support programs, and tracking adverse event reports
Personal and business contact information and preferences (such as name, job title and employer name, email address, mailing address, phone number, and emergency contact information)
Biographical and demographic information (such as date of birth, age, gender, marital status, and information regarding any parents or legal guardians)
Professional credentials, educational and professional history, institutional and government affiliations, background checks, performance reviews, and information of the type included on a resume or curriculum vitae education and work history
If you are a third party with whom we have or are contemplating a contractual relationship, such as a health care professional, we collect publicly available information related to your practice, such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence related information
Payment-related information we need to pay for services and products that individuals may provide to us (such as tax identification number and financial account information)
From health care professionals, we may collect information about the programs and activities in which you have participated, our interactions with you, and the agreements you have executed with us
Security and access credentials such as username and password that may be created in connection with establishing an account on our website or mobile application
Your photograph, social media handle or digital or electronic signature
If you are a visitor to a ForwardTx office location, we may collect information through closed circuit television (CCTV)
Other information you provide to us (such as in emails, on phone calls, through our websites or mobile applications, or in other correspondence)

How we use your Personal Data

To the extent permitted by applicable local law, we may use personal data for the following purposes:

Communicating with you about the products and services we offer, and responding to requests, inquiries, comments, and suggestions
Analyzing and enhancing our communications and strategies (e.g. effectiveness of emails or our websites and mobile applications)
Operating, securing, and improving our business (including both physical premises digital environments)
Developing, personalizing customer relationship management activities, including the delivery of programs and materials, as well as surveys and market research
Staffing, facilitating, conducting and managing clinical trials
Tracking and responding to safety and product quality concerns (including product recalls)
Complying with regulatory monitoring and reporting obligations (including those related to adverse events, product complaints, spend transparency, and patient safety)
Defining and managing appropriate patient engagement and enrollment activities
Identifying, interacting, and engaging with health care professionals, including thought leaders and external experts
Facilitating and improving our recruitment activities (such as processing employment applications, evaluating a job candidate for an employment activity, analyzing trends, and monitoring recruitment statistics)

We will specify the purpose and basis on which we intend to use personal data when we collect or begin using the personal information. In some situations, we may have a separate agreement or relationship with you with respect to a specific type of processing of your data, such as if you participate in a special program, activity, event, or clinical trial. These situations will be governed by specific terms, privacy notices, or consent forms that provide additional information about how we will use your information.

Sensitive Personal Data We do not use or disclose your sensitive personal data for purposes that are not necessary to provide our products or conduct health research as are reasonably expected by an average person engaging in these activities with us.

Personal Data We Share

ForwardTx shares personal data for the purposes described in either this Privacy Notice or through a specific “in-time” privacy notice provided at the time we collect the information.

The types of individuals or entities we share personal data with include:

ForwardTx affiliates and research partners
Service providers that perform services on our behalf, including:

Contract research organizations that conduct clinical trials on our behalf
Customer service and patient support providers (including for product quality and adverse event reporting etc.)
Data storage and analytics and technology providers (including technology support, marketing and advertising technology providers)
Event planning and travel organizations that help facilitate ForwardTx programs

Regulators worldwide, as required by law, including in connection with monitoring, review and approval of our studies, products and services, and adverse event reporting
Health care professionals, researchers, academics, and public health organizations
In addition, we may share your information to comply with legal and regulatory requirements, and protect against fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.
Unless prohibited by applicable law, we may disclose personal data as part of a corporate business transaction, such as a merger, acquisition, reorganization, joint venture or the sale of our assets. We may also disclose personal data to a successor entity in the event of insolvency, bankruptcy or receivership.

A list of such parties is available upon reasonable request using the details in the Contact Us section of this notice.

Note that some of the Automated Information providers we use on the Site may collect information about you, and we do not control such collection of data, or what such providers do with your data once they collect it.

Except in the event that our company undergoes a merger, corporate restructuring, or the sale of all or substantially all of our assets, we will not sell your Personal Data in exchange for money.

However, in the process of setting cookies and Automated Information, to provide ForwardTx with certain analytics services on our Site, some service providers (e.g. Google) may retain analytics data for their proprietary purposes including for cross context behavioral advertising. Since the retention of analytics data may impact the price of the analytics services to ForwardTx, it may be deemed a Sale of Personal Information. You have the right to opt out of this type of sale or sharing of your Personal Data to third parties and we have provided opportunities on the Site for you to exercise this right as well as by contacting us using details in the Contact Us section.

Cookies and Other Automated Information Collection

We, our service providers, and our business partners, may also collect certain information about the use of our websites and mobile applications by automated means, such as cookies, web beacons and other technologies (“Automated Information”). Please see our Cookies Policy for more information about cookies. We or our service providers and business partners may collect Automated Information about your online activities over time and across our own and third-party websites when you use our websites and mobile applications, including to deliver advertising-related content. In jurisdictions where Automated Information is considered personal data, or if we associate Automated Information with personal data, we will treat Automated Information as personal data and process such information in accordance with this Privacy Notice and applicable laws.

The information that we may collect from time to time by automated means includes:

Details about the devices that are used to access our websites or mobile applications (e.g. IP address, and type of operating system and web browser)
Dates and times of visits to, and use of, our websites and mobile applications
Details about your interactions with emails that we may send you, including the links on which you click and your interactions with our linked sites
Information about how our websites and mobile applications are used (such as the content that is viewed on our websites and how users navigate our pages)
URLs that refer visitors to our websites

We may use Automated Information for a variety of purposes, including:

To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality;
To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site, keeping track of your specified preferences; and
To deliver content relevant to your interests on our Site and third-party sites based on how you interact with our advertisements and/or content.

We may also obtain analytics services from Google LLC (“Google”) through use of their Google Analytics. In order for Google to provide this service to us, they place a cookie or cookies on your Device which allows Google to track certain information about you, your technology or activities online, such as your geographic location, the IP address from which you connected to the Internet, information about your Device, your browser and your Internet provider. We do not control such data collection or how Google uses the data they collect.

Legal basis for processing data

In some cases, ForwardTx has a legitimate interest to process the personal data that we collect, such as to operate, evaluate and improve our business; to facilitate and manage clinical trials or other patient advocacy and engagement programs; to promote scholarly research; to support our recruitment activities; or to facilitate a sale of assets or merger or acquisition. We may also process your personal data as necessary for the protection against criminal offences, safeguarding of domestic law, and the maintenance of a safe workplace for staff.

In other cases, ForwardTx processes personal data to fulfill our contracts with our business partners, such as healthcare professionals or our research partners.

It may be also necessary for ForwardTx to process personal data to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide.

ForwardTx’s processing of certain health and other associated information may be necessary to comply with our legal obligations, and for reasons of public interest in the area of health or for scientific or historical research purposes, such as with respect to adverse event and product safety reporting.

ForwardTx may also process personal data as specifically permitted by applicable legal requirements, such as laws and regulations that authorize ForwardTx to process personal data for purposes of clinical trials.

If ForwardTx relies on consent for the processing of your personal data, we will seek such consent at the time we collect your personal data. For information on how to withdraw consent, please see the “Personal Data Access Rights” section of this Privacy Notice.

Response to Do Not Track signals

Do Not Track (“DNT”) or “Global Privacy Control,” is a preference setting offered by various internet browsers whereby a signal is automatically sent by the browser to each website visited requesting that the user’s activities are not tracked by that website and that the website does not enable onward tracking to other websites. You can usually access your browser’s DNT option in your browser’s preferences. If that occurs, the website visited will not recognize you upon return to that website, save your passwords or usernames, and some other features of a website may become unavailable or not function properly. We have configured our Site with the intent that it honors DNT signals from most browsers. When a user’s browser is set to DNT, we will disable cookies related to marketing and targeting

International data transfers

We may transfer your personal data to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. The countries to which we transfer personal data may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal data across borders (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we consider a variety of requirements that may apply to such transfers, but in any event we will only transfer your data to a destination and in a manner that ensures your personal data will remain protected to the same or equivalent level as in the country of origin. This may include standard contracts that have been provided by the relevant regulatory authorities and which commit the recipient to process personal data in accordance with applicable law in the country of origin.

Personal Data Retention

We store personal data as needed to accomplish the purposes identified in this Privacy Notice and to meet legal requirements, including to comply with law, and for record retention, resolving disputes, and enforcing our agreements. We will not retain personal data or sensitive personal data for longer than is reasonably necessary for the purposes disclosed above. Our retention of your personal data is governed by applicable law. This storage period may extend beyond the term of your relationship with us.

When we no longer need personal information, or in any event, after legal authority to retain it has expired, we will destroy personal data in accordance with local law and pursuant to our relevant procedures.

Personal Data Access Rights

Individuals are able to exercise certain rights in relation to the personal data that we may have collected about you. We will not discriminate against you for exercising any of your rights over your personal data. However, if you exercise these rights, it may limit our ability to process your personal data and we may not be able to provide the products or services you requested.

We reserve the right to verify the identity of an individual in connection with any requests regarding personal data, to help ensure that we provide the information to individuals to whom the information pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information.

If we receive personal data about you from a third party, we will protect it as set out in this privacy notice.

Withdrawal of consent

Where you have provided consent to us to process your personal data, you may withdraw such consent by following the instructions provided at the time of collection or by contacting us using details in the Contact Us section below. In some instances, withdrawing your consent may mean we can no longer provide products or services to you or otherwise engage with you.

Access to personal data

You may request access to the personal data that we maintain about you. You may request to correct any errors in your personal data. In the event we cannot comply fully or at all, with your request, we will notify you of the reasons for this.

Objection to and deletion of personal data

To the extent provided by applicable law, you may object (opt-out) at any time on legitimate grounds to the processing of your personal data or request that we delete your personal data from our records. In some cases, we may not be able to comply with your request or comply fully. In the event we cannot comply, we will notify you of the reasons for this.

In any event, you have the right to file a complaint with a regulator or data protection supervisory authority in your jurisdiction.

You also have the right to object if we use your Personal Data for direct marketing purposes. This includes your right to request that your Personal Data not be Sold to or Shared with third parties for their own proprietary purposes including for cross-context behavioral advertising, which is the targeting of advertising to a consumer based on that consumer’s Personal Data from a number of sources. If you wish to modify your preferences in respect to updates or notifications, you can contact us using the details provided in the Contact Us section below. All commercial and marketing communications (e.g. notification emails and newsletters) include instructions on how to opt out of those communications in the future.

When submitting a request any of these rights, please describe your relationship with us and your request, with sufficient detail to allow us to properly understand, evaluate, and respond to it. We will need to verify your identity before processing your request, which may require us to request additional personal data from you.

If you would like an authorized agent to exercise these rights on your behalf, you (or the authorized agent) must provide a written request including your full name and all contact details (e.g. email address, mailing address) that we have in our records and with which we can authenticate you, as well as (if applicable) the relationship with ForwardTx. The written request must include the full name and preferred contact details of the authorized agent. We may deny a request from an agent who cannot meet these requirements.

If you believe that we have breached relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Please note that due to the confidentiality restrictions in place to protect participants in our trials, ForwardTx cannot identify an individual trial participant and therefore, we cannot respond to any request from a trial participant to withdraw from any ForwardTx sponsored trial or to exercise the personal data access rights outlined above. Such requests must be directed to the respective study doctor or study team who will advise you further on the necessary procedures.

Minors

We do not knowingly collect personal data from children under age 16 through our websites or mobile applications. If we learn that we have collected personal data directly from a child under the age of 16 through our websites or mobile applications, we will delete that information.

How we Protect Personal Data

ForwardTx maintains reasonable administrative, technical and physical safeguards designed to protect the personal data we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Although we will do our best to protect your Personal Data, please note that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. We will comply with all applicable laws in respect of a data breach.

Links to Websites and Third-Party Content

For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by ForwardTx. The websites and third-party content to which we link may have separate privacy notices or policies. ForwardTx is not responsible for the privacy practices of any entity that it does not own or control.

Updates to our Privacy Notice

ForwardTx reserves the right to change this Privacy Notice at any time. When we update this Privacy Notice, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Notice and providing other notification as required by applicable law. We may also notify you of changes to the Privacy Notice in other ways, such as via email or other contact information you have provided.

Contact us

You may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices, or to request access to or correction of your information. When raising a request or complaint, please provide sufficient details (including your relationship with us) and any relevant documentation. The contact information for our global Privacy Office:

ForwardTx
Attn: Privacy Officer
11029 Legacy Boulevard
Palm Beach Gardens
FL 34410, USA
privacy@forward-tx.com