Introduction

4D pharma is a group of companies with operations globally. The 4D pharma enterprise (“4D pharma”, “we,” “us,” “our”) includes the parent company 4D pharma plc, and its subsidiaries and affiliates (4D Pharma Leon SLU, 4D Pharma Research Limited and 4D Pharma Cork Limited). We are committed to privacy compliance and to earning our users’ (“ you”, “your”) trust.

To earn that trust, we aim to be transparent and ensure you understand our privacy practices including the information we collect, why we collect it, how it is used and your choices regarding your personal information.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

  1. Who is 4D pharma?
  2. Who does this Privacy Notice apply to?
  3. What information does 4D pharma collect about me?
  4. What cookies and similar technologies does 4D pharma use?
  5. Why does 4D pharma process my personal data for and what are the legal bases 4D pharma relies on?
  6. Who does 4D pharma share your information with and why?
  7. How does 4D pharma send information outside of my country?
  8. What are my privacy rights?
  9. How does 4D pharma protect my personal information?
  10. How long does 4D pharma retain my personal information?
  11. Can this Privacy Notice change?
  12. How can I contact 4D pharma?

1) Who is 4D pharma?

We are the operator of this website https://www.4dpharmaplc.com and will be the controller of your personal data.

Entity

Address

4D pharma plc

9 Bond Court, Leeds LS1 2JZ, United Kingdom

You can contact our Data Protection Officer at [email protected].

2) Who does this Privacy Notice apply to?

This Privacy Notice applies to this website https://www.4dpharmaplc.com and our services, which are operated by us.


3) What information does 4D pharma collect about me?

Information you give us

You choose to give us certain information when using our services. This may include:

  • Contact details, including your name and surname and email address and the name of the company you work for.
  • Professional information, including job title, educational information, professional qualifications, work experience, board memberships, professional networks and programs and activities in which you participated.
  • Payment related information such as your bank details, where necessary for payment of invoices.
  • Marketing and Communications, including our records of marketing and other communications we have shared with you, and your preferences where you have informed us that you do not want to receive marketing data from us.
  • Adverse even reporting data, including certain health and other associated information as necessary to report and adverse event under the applicable laws.

Information we receive from others

  • Other Partners: We may receive information about you, such as your contact details, from our partners who operate within the framework of pharma.

Information collected when you use our services

  • Device information: We collect information from and about the device(s) you use to access our services, including:
    • hardware and software information such as IP address, device ID and type, device-specific settings and characteristics, browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser;
    • information on your wireless and mobile network connection, like your service provider and signal strength.
  • Usage Information: We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, referring webpage address).
  • Location (up to country level): We can identify the country you are located based on your IP address.

If the personal information we hold about you is incorrect, please let us know.

You may decide not to provide your personal information to us. However, in that case, please note that we may not be able to fully provide you with all our services.

4) What cookies and similar technologies does 4D pharma use?

Please see our Cookie Notice for more information on why we use them and how you can better control their use, through your browser settings and other tools.

5) Why does 4D pharma process my personal data for and what are the legal bases 4D pharma relies on?

We may process your personal data for the purposes below and based on the following legal bases:

Purpose

Legal Basis for processing

Conduct our business operations which includes communicating with you about our organisation, research and products, about your engagement with us, such as changes in our terms, about managing our collaboration and payments, and inviting you to our events or to participate in our activities, such as advising on clinical studies, among others.

Necessary for the performance of our contract with you or the organisation you represent.

Communicating with you at your request to provide you with information about our organisation, research and products.

Necessary for taking steps prior to entering into a contract with you or the organisation you represent.

In case, the request is not related to any current or future contract with us contract, we may communicate with you based on our legitimate interest pursued by us or our service providers acting on our behalf or by a third-party insofar as such interests do not pose a high risk to your rights and freedoms.

Our legitimate interest is responding your query as part of our regular day-to-day operations.

Ensuring proper administration of our business which includes keeping appropriate records, resolving complaints, managing our business relationships and opportunities and asking you to leave a review or take a survey.

Necessary for our legitimate interest pursued by us or our service providers acting on our behalf or by a third-party insofar as such interests do not pose a high risk to your rights and freedoms.

Our legitimate interest is ensuring the continuity of our service.

Preventing, detecting and fighting fraud or other illegal or unauthorized activities which includes monitoring operations, user activity and networks for fraud prevention and crime detection purposes, including information from third parties who may monitor our website and systems and alert us about suspicious activities, auditing our systems and deploying security measures.

Necessary for our legitimate interest pursued by us or our service providers acting on our behalf or by a third-party insofar as such interests do not pose a high risk to your rights and freedoms.

Our legitimate interest is preserving the security of our service.

Performing service enhancement activities using aggregated and non-aggregated information, which includes conducting statistical analysis on online activity, usage, browser, device and other data.

Necessary for our legitimate interest pursued by us or our service providers acting on our behalf or by a third-party insofar as such interests do not pose a high risk to your rights and freedoms.

Our legitimate interest is making services and features more relevant and improving user experience.

Sending marketing communications about our services and our organisation.

Where you signed up for our newsletter or other content, such as regulatory news, announcements or promotional offers, we will send you relevant information based on your consent.

Where consent is not required, as you or the company you represent are an existing customer who purchased or negotiated to purchase a similar service in the past, we may send you marketing communications based on our legitimate interest pursued by us or our service providers acting on our behalf or by a third-party insofar as such interests do not pose a high risk to your rights and freedoms.

Our legitimate interest is promoting our business and to provide you with offers of relevant services.

We will include an unsubscribe link in all our email communications, which removes you from receiving further communications.

Establishing, exercising or defending legal claims in suspected or actual legal proceedings.

Necessary for compliance with applicable laws and regulations.

Exercising or performing any right or obligation which is conferred or imposed by law on us.

Necessary for compliance with applicable laws and regulations.

Where we are legally required, we may process your personal data in connection to specific legislation, statutory codes of practice and other legal or tax related obligations.

This includes complying with regulatory monitoring and reporting obligations (including those related to adverse events, product complaints, speed transparency, and patient safety).

Necessary for compliance with applicable laws and regulations, 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.

6) Who does 4D pharma share your information with and why?

We may share your personal data with:

With our service providers and partners

We use third parties to help us operate and improve our services and facilitate the fulfilment of essential service functions. These third parties assist us with various tasks, including personal information hosting and maintenance, security tools, marketing and our partners among others.

In corporate transactions

We may transfer your personal information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

When required by law

We may disclose your personal information if reasonably necessary with regulators, law enforcement agencies or where mandatory under a court order: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person. This includes regulators worldwide, as required by law, including in connection with monitoring, review and approval of our studies, products and services, and adverse event reporting.

For members/shareholders only:

Please note that as a publicly listed company, 4D pharma has certain legal obligations to disclose member/shareholder data to third parties or to make the data public (for example, under the UK S116 Companies Act). Please rest assured that 4D pharma will only disclose the data as is strictly necessary to comply with its legal obligations and in compliance with the applicable privacy laws.

To enforce legal rights

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With other entities within 4D pharma Group

When it is necessary for operational reasons such as the use of a group-wide logistics and IT infrastructure and for any administrative purposes to organise, run our organisation and decide on future strategies.

7) How does 4D pharma send information outside of my country?

When we send your personal information outside of your country, we have in place adequate safeguards to do so. This includes EU standard contract clauses approved by the European Commission or other suitable safeguard to permit personal information transfers from the United Kingdom and the European Economic Area to other countries. We may transfer your data otherwise permitted by applicable EEA requirements, for example where the transfer is necessary for important reasons of public interest (such as adverse event reporting).

You may request further information on the measures used for the international transfers at [email protected].

8) What are my privacy rights?

In certain circumstances, you may exercise the rights available to you under applicable data protection legislation as follows:

  • If you wish to access, correct, update or request deletion of your personal information.
  • You can object to processing of your personal information when such processing is based on legitimate interests, ask us to restrict processing of your personal information or request portability of your personal information.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. You can contact the UK Information commissioner's office here: https://ico.org.uk/. A list of European data protection authorities is available here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

You can exercise your rights at any time by contacting us using the contact details below in Section 12 “How can I contact 4D pharma?”.

We respond to all requests we receive from users in accordance with applicable data protection laws. We may ask you to provide proof of identity before we can answer the above requests. In some cases, we may reject requests for certain reasons (for example, if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user).

9) How does 4D pharma protect my personal information?

We have implemented, and will maintain current, reasonable physical, technical, and organizational security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

10) How long does 4D pharma retain my personal information?

We generally retain personal data for as long as needed for the specific business purpose(s) for which it was collected. In some cases, we may be required to retain your personal data for a longer period where applicable laws or regulations require or allow us to do so.

Where possible, we aim to anonymise the information or remove unnecessary identifiers from records that we may need to keep for longer periods beyond the specified retention period.

In case of any questions relating to data retention, please contact us at: [email protected].

11) Can this Privacy Notice change?

This Privacy Notice may be amended from time to time. We will post any changes we may make on this page and, where appropriate, notify you via e-mail. When amendments are made, we will update the " Last updated" date at the bottom of this Privacy Notice.

12) How can I contact 4D pharma?

If you have questions regarding your privacy and rights, please let us know how we can help.

Last updated: January 2022

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