Privacy Notice
This Privacy Notice explains the practices that Inspirna Inc. (“Inspirna”, “we”, “us”) follows in connection with the Personal Data that we collect through this website, when you contact us directly and through our clinical research.
What Is Personal Data?
For the purposes of the work that Inspirna performs and the regulations that Inspirna needs to comply with, Personal Data refers to any information that relates to an identified or identifiable individual such as a name, email, mailing address, phone number, or any information related to an individual’s health for the purpose of healthcare research (“Personal Data”).
How We Collect and Process Your Personal Data
Requests for Contact
We collect Personal Data provided directly by you through communication with Inspirna through web forms, email or by phone. We collect your name, phone number, email address and the reason for the communication.
We use your Personal Data to acknowledge and respond to your request.
Request for Information or Participate in a Clinical Trial
Individuals interested in participating in a clinical trial, can visit this link on our website or reach out to one of our team members through clinicaltrials@inspirna.com.
When you contact us for this purpose, we collect your email address, the reason for your interest in the clinical trial, and any other information that you may share with us. This information is used to provide you with additional details about the clinical trial you are interested in and to connect you with one of our clinical trial sites if you are interested in any of our clinical trials.
Signing up for Newsletter
We collect your full name, email address, and company name, if you agree to sign up for email communications with Inspirna.
We send emails to the email address you have provided to keep you updated with information about Inspirna and to send you information that we believe will be to your benefit. You may unsubscribe to any of our communications at any time.
Clinical Research
The patient data that we obtain and use from the clinical trials is pseudonymized and managed through an identifier that we cannot link back to the patient. Only the clinical site that collected the patient’s Personal Data is able to link it back to the patient’s identity. We use patient’s Personal Data to review the outcomes of the clinical trial.
Job Applicants
We collect your contact information and details related to your professional qualifications,
provided directly by you if you apply for a position through our website via the “Contact Us” page, recruiting firms, or through referrals from current Inspirna employees whom you have given consent to share your profile with us. We use this data to determine if your expertise fulfills the requirements of the role you are applying for and to contact you to continue the recruitment process.
Website Interaction
As you navigate through and interact with our website, we collect certain information about your device, browsing actions and patterns, including:
- Details of your visits to our website, including traffic data, location data, logs and other communication data and the resources that you access and use on the website.
- Information about your device and internet connection, including your IP address, operating system, and browser type.
We use cookies, with your consent, to gain insights into how our visitors navigate the website in order to optimize your web experience. Please read our Cookie Notice for details on the cookies we use.
Our Legal Basis for Processing Your Personal Data
In order to comply with various privacy and data protection regulations around the world and specifically to comply with the General Data Protection Regulation (“GDPR”) in the European Union (EU) and the Data Protection Act of 2018 in the United Kingdom (UK), we require to provide a legal basis for the processing of your Personal Data.
Inspirna will not process your Personal Data unless we have a legal justification to do so. Inspirna will only process your Personal Data if:
- We or the clinical sites we partner with, have obtained your explicit consent prior to the processing of your Personal Data;
- If we need your Personal Data to perform a contractual obligation to which you are a party or where you have requested us to complete a contractual request;
- If we need to process your Personal Data to fulfill our legal and regulatory obligations;
- If we have a legitimate interest that will not put your fundamental rights and freedoms at risk.
Who Has Access To Your Personal Data?
Inspirna will only disclose your Personal Data to the following parties under specific circumstances:
- To Inspirna personnel with a need to know, if required, to fulfill your request;
- To service providers that support our systems or support the activities of the clinical trial, including the clinical sites that hold Personal Data about patients;
- To law enforcement, regulatory bodies or courts, when we are required to do so under applicable laws and regulations;
- In connection with the sale or reorganization of all or part of our business, as permitted by law.
How Do We Keep Your Personal Data Safe?
Inspirna is committed to protecting the Personal Data we collect, process, and disclose about you. We maintain appropriate safeguards and take reasonable steps to protect your Personal Data. We ensure that we limit use of your Personal Data and that we disclose it only to the parties that have a legitimate reason to have access to it.
We also ensure that all the parties that we disclose your Personal Data to, internal and external to Inspirna, have contractual obligations in place to protect the security and the confidentiality of your Personal Data at the same level that Inspirna does.
Where Is Your Personal Data Stored?
Your Personal Data will be transferred to systems that reside in the US. We ensure that your data is safeguarded and work with our partners to ensure that the risks to your privacy are minimized.
We have implemented Standard Contractual Clauses for parties in the EU and International Data Transfer Agreements for parties in the UK who will transfer Personal Data to Inspirna in the U.S.
How Long Do We Retain Your Personal Data?
Inspirna will retain your Personal Data according to our internal Retention Policy for the purpose of research, communications and to comply with legal and regulatory obligations.
What Rights Do You Have Regarding Your Personal Data?
Subject to any exceptions provided by law, you have the right to request access to, update or delete your Personal Data.
You also have the right to request restriction of or object to the processing of your Personal Data. And you have the right to request to have your data provided to you in an electronic format if you desire to have a copy of it.
On each particular case we will inform you of the consequences of your request and if there are any exemptions to honoring your requests based on legal or contractual requirements.
During a clinical trial your rights to access, update or delete your pseudonymized Personal Data may be limited as permitted by law. Specifically, we need to process your data in specific ways in order to maintain the reliability and integrity of the clinical trial for reasons of public interest in public health and for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.
How To Exercise Your Personal Data Rights
To submit any request about your Personal Data you may contact us via email at dataprivacy@inspirna.com.
General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Inspirna has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:
by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
You may find the contact of the EU Supervisory Authorities here.
EU/UK individuals – Right to Lodge a Complaint with a Supervisory Authority
If you reside in the EU or UK and want to lodge a complaint with a Supervisory Authority (Data Protection Authority) you may do so in the country where you reside, where you work or where you may have experienced an issue with the processing of your Personal Data.
How To Contact Us
If you have any further questions regarding the Personal Data that Inspirna or any of our partners collect and process or if you have feedback regarding this Privacy Notice, you may contact us at: dataprivacy@inspirna.com.
Changes To This Privacy Notice
We reserve the right to modify or update this privacy notice as we consider necessary periodically or in accordance with privacy legislation that we need to comply with. Should any revisions be made to this privacy notice, we will publish the revised version here, along with an updated date of revision, and take reasonably practical measures to inform you of any changes.