Privacy Policy

Last Updated November 2021

Imagen Therapeutics, Ltd. (collectively “Imagen”, “we”, “us”, or “our”) is committed to protecting your privacy and making it easier and more efficient for you to interact with us. We recognize that it is critical for you to be confident that your privacy is protected when you visit our website, use our products and services, and communicate with us.

This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information through our website, products, services, and communication tools (together “Imagen services”). By using Imagen services, you are consenting to the practices described in this Privacy Policy.

Controller of Personal Information

Any personal information provided to or gathered by Imagen is controlled primarily by Imagen Therapeutics Ltd.

What Personal Information We Collect

Imagen does not collect any personal information about you unless you provide that information voluntarily by filling out a form, interacting with a chat bot, sending an email, placing an order, applying for an employment opportunity, or accessing your account. You are under no obligation to provide us with personal information of any kind; however, your refusal to do so may prevent you from using certain features of Imagen services.

The personal information we may collect includes:

Personal Data

Personal identifying information such as

• Your name, address, email and phone number;
• Your employer and job role;
• Your location information;
• Your areas of interest relating to our products, services or businesses; and
• Content of your reviews, emails and online chat or messages with us. The information collected is not limited to text characters and may include audio, video, and graphic information formats included in the message.

Derivative Information (Log Data)

Our servers may automatically collect information about your use of our website, such as:

• IP address used to connect your computer to the internet;
• Login information, email address, and password;
• Location of your device or computer and your access time;
• Your browser and operating system;
• Webpage visit and content use history, including full URL clickstream to, through, and from our website, as well as date and time, products and content you viewed or searched for, content downloads, streams, and playback details, download errors, length of visits to certain pages, and page interaction information; and
• Imagen Services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, your settings preferences and backup information, information about uploaded files such as the file name, dates, times and location).

No Collection of Children’s Personal Information

Imagen does not knowingly collect personal information from children under the age of 13 or create profiles of children under the age of 13. Users are cautioned, however, that the collection of personal information submitted in an email will be treated as though it was submitted by an adult. If you become aware of any data we have collected from children under age 13, please contact us at [email protected].

How We Use Your Personal Information

Having accurate information about you allows us to deliver, develop, and improve Imagen Services and provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you to:

• Communicate with you via different channels (e.g., by phone, email, or live chat) to address your questions and concerns; (Legal basis for processing your personal data: consent, performance of contract and/or to take steps at your request prior to entering into a contract)
• Ensure smooth connection with and proper function of our website and optimize user experience of our website. The log files enable the evaluation of system security and stability; (Legal basis for processing your personal data: legitimate interest for running our business, provision of administration and IT support, and developing our products/services)
• Verify and/or authenticate your identity, access rights, privileges, etc; (Legal basis for processing your personal data: performance of contract, legitimate interest for network security and to prevent fraud)
• Deliver, fulfil and manage Imagen Services and other transactions; (Legal basis for processing your personal data: performance of contract)
• Improve Imagen Services, troubleshoot and solve problems, and analyse usability and effectiveness; (Legal basis for processing your personal data: legitimate interest for running our business, provision of administration and IT support, and developing our products/services)
• Understand your needs and identify your preferences so as to recommend features, products, and services that might be of interest to you; (Legal basis for processing your personal data: legitimate interest to study how customers use our products/services, to develop them and grow our business)
• Deliver targeted advertising, newsletters, marketing, events and other information that might be of interest to you; (Legal basis for processing your personal data: legitimate interest to study how customers use our products/services, to develop them and grow our business)
• Comply with legal obligations, such as assisting law enforcement and responding to subpoena; (Legal basis for processing your personal data: legal obligation)
• Prevent misuse and misbehaviour, monitor against theft, and protect against criminal activity; (Legal basis for processing your personal data: legal obligation, legitimate interest for network security and to prevent fraud)
• Use depersonalised and aggregated information to develop reports and analysis for research and for other legitimate business purposes. We combine your information, in aggregated form, with those of other users to generate summarised reports that help us to optimise our services and products. (Legal basis for processing your personal data: legitimate interest to develop our business and to inform our marketing strategy)

Ways We Collect and Use Personal Information, and Your Options

Contact Form(s)/Contact by Email/Live Chat

If you send us inquiries or requests via our contact forms, email or live chat, or register for a webinar or event, your details, including the contact information you have provided there, will be stored for the purpose of processing the inquiry and fulfilling the request and for follow-up actions.

Online Account

We provide an online database for users to search relevant information of our models. To access the database, you will need to create an account and provide us with personal information that includes your name, company, email, and a password. Your personal information will be used to verify and/or authenticate your identity, access rights, privileges, etc. Your refusal to provide personal information will prevent you from using the database. By using Imagen’s database you agree to its Terms of Use.

Job Application Form

If you apply for a job with us through our website, you will need to register and create a user profile. We collect and use the following personal data during registration and setup:

• First name
• Last name
• User’s email address
• Date and time of registration

Additional information can be provided voluntarily (e.g. phone number). Information required for the purpose of registration are marked with an asterisk in the input mask as a mandatory field. With your user account, you will have the possibility to search for and apply for jobs at Imagen. Your data will be deleted when your user account is closed and if no legal retention obligations exist. You can usually change and/or delete your user account, including the data you have provided, directly in your user account after logging in or by sending a message to our Human Resources Department at [email protected].

Cookies

We may use cookies created by our website to help customize and improve your experience. A cookie is a unique text file stored on your computer by your web browser. These text files are used as a means of distinguishing among users of a website. A cookie will not include personal information, unless you have volunteered that information. One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize pages on our website or register for a service, a cookie helps us to recall your specific information during subsequent visits. When you return to the website, the information you previously provided can be retrieved from the cookie file, allowing you to easily use customized features. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer (or delete cookies already present). If you choose to decline cookies, you may not be able to fully experience certain features of our website.

We may also partner with selected third-party vendors, such as HubSpot and Google Analytics, to allow tracking technologies and remarketing services on our website through the use of first-party cookies and third-party cookies. By accessing our website, you consent to the collection and use of your information by these third-party vendors.

HubSpot

Our website uses HubSpot, a marketing automation tool that allows us to accept forms and respond to our users with the content they request. HubSpot uses cookies to help gauge the interest of our users, make repetitive tasks easier, serve personalized content, and facilitate our marketing. You consent to accepting HubSpot cookies when you visit our website. To reject cookies from HubSpot, you can turn them off in your web browser.

Google Analytics

Our website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses cookies. The information generated by the cookies about your use of our website is usually transferred to a Google server in the United States and stored there. We use Google Analytics only with IP anonymization enabled. This means that Google will truncate the IP address of users within Member States of the European Union or in other signatory states to the Agreement on the European Economic Area to exclude any personal relationship. You can prevent Google from collecting the data generated by the cookies and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at http://tools.google.com/dlpage/gaoptout.

Newsletter and Marketing Communications

You will receive marketing communications from us if you have:

• subscribed to our newsletter;
• registered for our webinars or other events; or
• used or expressed an interest in our products or services.

We rely on legitimate interest to continue sending you marketing communications to let you know of our products or services or any events that we are running. In addition to the email address required for sending the newsletter, we store the IP address via which you have registered for the newsletter as well as the date and time of registration so that we can trace any possible misuse at a later point in time. You can opt-out from receiving marketing emails from us by following the links at the bottom of any of our marketing emails you may receive. After your cancellation, your email address will be deleted from our newsletter distribution list immediately.

Confidentiality and Security of Personal Information Collected

Imagen is strongly committed to protecting personal information against unauthorized access, use or disclosure. Consequently, Imagen limits employee access to personal information to only those employees who need access to the information in the performance of their official duties. Employees who have access to such information follow appropriate protocols in connection with the use and disclosure of personal information. Additionally, Imagen has implemented measures to safeguard the personal information and to improve the security of its information technology, including, but not limited to, authentication, authorization, monitoring, auditing, and encryption. These security measures have been integrated into the design, implementation, and day-to-day operations of our website as part of our continuing commitment to the security of electronic content as well as the electronic transmission of information. For website security purposes and to maintain the availability of our website for all users, Imagen employs software to monitor traffic to identify unauthorized attempts to upload or change information or otherwise damage our website.

While we use administrative, technical, and physical security measures to help protect your personal information and have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

Disclosure of Your Personal Information

We may share information collected about you with third parties in certain situations:

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.

We may share your information with third parties that perform services for us or on our behalf, including data analysis, email delivery, hosting service, customer service, and marketing assistance.

We may share your information with our affiliates who honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

We may share your information with our business partners to offer you certain products, services or promotions.

Some Imagen products and/or services may be co-branded and offered in conjunction with another company. If you register for or use such products and/or services, both Imagen and the other company may receive information collected in connection with the co-branded product/services.

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter into bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline to honor commitments we made in this Privacy Policy.

Your voluntary provision of personal information to Imagen constitutes your consent to the collection and disclosure of the information by Imagen for the above purposes. In other situations, we will notify you when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

Furthermore, when you post comments, contributions or other content to our website or during a webinar, your posts may be viewed by all users and may be publicly distributed outside our website permanently. We are not responsible for the actions of third parties with whom you share personal or sensitive information, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

International Data Transfer

We may transfer to, and store the data we collect about you in, countries other than the country in which the data was originally collected, including the United States or other destinations outside the European Economic Area (“EEA”) and the United Kingdom. Those countries may not have the same data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA and outside the United Kingdom.

If you are located in the EEA or the United Kingdom, we will only transfer your personal data if:

the country to which the personal data will be transferred has been granted a European Commission adequacy decision; or we have put in place appropriate safeguards in respect of the transfer, for example we have entered into European Union standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by a European Union or United Kingdom supervisory authority.

Access to and Change of Your Information and Privacy Preference

You may submit a request to Imagen to inquire whether personal information pertaining to you has been collected. Any such request shall be made in writing and must be accompanied by reasonable proof of identity of the user. Reasonable proof of identity may include verification of a signature, inclusion of an identifier generally known only to you, or similar appropriate identification. Please submit your request to: [email protected]. Imagen will undertake reasonable steps to permit you to correct, amend, or delete your information demonstrated to be inaccurate or incomplete.

Account Information

You may at any time review or change the information in your account or terminate your account by:

Logging into your account settings and updating your account; or

Contacting us at [email protected].

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies

If you want to browse our website without being tracked the browsing history, you may do so by blocking cookies on your browser.

Emails and Communications

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

Noting your preferences at the time you register your account;

Logging into your account settings and updating your preferences; or

Contacting us at [email protected].

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

Retention of Information Collected

The information collected by Imagen is retained by Imagen as determined by relevant legal retention periods. Personal information in your account will be retained until you choose to remove it or until the account is closed. We retain your personal information for as long as is necessary to fulfil the purpose for which it was collected. We may retain your personal information for longer period due to reasons such as security and fraud prevention, tax or accounting record keeping, or complying with legal or regulatory requirements.

Links to Third-Party Websites

Our website may provide links to third parties as a convenience in locating relevant information and services. We do not take any responsibility for the content, the accuracy of the information and/or quality of products or services provided by or advertised on these third-party websites. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from our website.

Your Data Protection Rights

If you are a “data subject” under applicable data protection law in the EEA or United Kingdom, you will have the following rights in relation to personal data that we hold about you:

• Right to Access – to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
• Right to Rectification – to request that we rectify or update any personal data that is inaccurate, incomplete or outdated;
• Right to Erasure – to request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
• Right to Restriction of Processing – to request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
• Right to Withdraw Consent – where you have given us consent to process your personal data, to withdraw your consent;
• Right to Data Portability – to request that we provide a copy of your personal data to you in a structured, commonly used and machine-readable format in certain circumstances;
• Right to Object – to object to the processing of your information for certain purposes; and
• Right to Object to Automated Decision Making – We use automated decision-making and profiling on our website. You have the right to object to our use of automated decision-making and profiling. You can do so by opting-out of cookies and similar technologies in accordance with the methods described in the relevant section above.

To exercise your rights as set out above or to make a complaint or submit an inquiry about our privacy practices, please contact us at [email protected].

User’s Responsibility

While we are committed to protecting your privacy, Imagen cannot and does not guarantee absolute privacy. You are responsible for safeguarding your passwords for access to your account and are responsible for all actions made using your password. You will not share your passwords or provide access to another individual using your password.

Changes to This Privacy Policy

Imagen will occasionally update this Privacy Policy to reflect changes in our practices. When changes are made to this Privacy Policy, we will revise the “last updated” date at the top of this page. We encourage you to periodically review this policy to be informed of how Imagen is protecting your information.

Disclaimer

The information provided in this Privacy Policy should not be construed as giving business, legal, or other advice, or warranting as fail proof, the security of information provided through our website.

Contact Us

If you have questions or comments about this Privacy Policy, please contact us at:

Imagen Therapeutics, Ltd.,
Unit 2 & 2a Enterprise House
Lloyd Street North

Manchester, M15 6SE

Attention: Legal Department