Last updated: May 8th, 2024
Sunflower Therapeutics, PBC. (“Sunflower Therapeutics”, “we”, “us”, or “our”) is committed to respecting your privacy. This Privacy Policy explains our practices regarding the collection, use, and disclosure of information that you (“you” or “user”) may provide to us through your use of our website located at www.sunflowertx.com, our social media pages, and any other websites that we link to this Privacy Policy (collectively, our “Website”).
If you have entered into a separate agreement with us, that separate agreement shall control, and only those terms within this Privacy Policy that do not conflict with such separate agreement shall apply. If you have any questions regarding this Privacy Policy, please contact us at privacy@sunflowertx.com.
By accessing the Website, you agree to be bound by this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Website. Each time you use the Website, the current version of this Privacy Policy will apply. Accordingly, when you use the Website, you should check the date of this Privacy Policy (which appears at the top) and review any changes since you last reviewed the Privacy Policy.
Information we collect
We collect two types of information from users of our Website: “Personal Information,” which is information that you provide that can be used to identify you (such as your name or your email address), and “Aggregate Information,” which is information that cannot be used to identify you (such as frequency of visits to the Website and your browser type).
INFORMATION YOU PROVIDE TO US
We collect Personal Information that you voluntarily provide to us when you use our Website. For example, you may provide us with your contact information such as your email address, first and last name, the content of your communication, or other Personal Information when you choose to submit such information to us through email, an online form, or other method (such as contacting us through the Contact Us feature on our Website). If you interact with us on social media, we may collect your social media profile information, your communications with us, and your communications and posts on our social media pages.
INFORMATION WE AUTOMATICALLY COLLECT
When you use our Website, we automatically receive and collect information from your device. This information includes the following:
- Information about your device, such as the operating system, hardware, system version, Internet Protocol (IP) address, device ID, and device language
- The specific actions that you take when you use our Website, including but not limited to the pages and screens that you view or visit, search terms that you enter, and how you interact with our Website
- The time, frequency, connection type, and duration of your use of our Website
- Information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message
- Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (as further described below)
- Your general geographic location (based on your IP address)
- Pages you visited before or after navigating to our Website
EMPLOYMENT
If we have collected your Personal Information through our “Join Us” page in response to a job opening, you are giving us permission to use and retain your Personal Information for the purpose of evaluating your application for employment consideration for the specific position that you applied to, as well as other roles at Sunflower Therapeutics. This Personal Information may be processed and stored by a third party talent tracking solution provider as well as with vendors, consultants, and other service providers who need access to such information to carry out work relating to the recruitment process on our behalf.
AGGREGATE INFORMATION COLLECTED
Aggregate Information is information that does not identify you. Aggregate Information may be collected when you use our Website, independent of any information you voluntarily enter. Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains. We may collect, use, store, and transfer Aggregate Information without restriction.
COOKIES AND ANALYTICS
Like most websites, our Website may use “cookies.” Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to help us identify you when you come to our Website.
Our Website collects cookies and may use cookies for reasons including, but not limited to:
- Analyzing our web traffic using an analytics package
- Testing content on the Website
- Storing information about your preferences
- Recognizing when you return to the Website
Overall, cookies help us provide you with a better website experience by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or device, or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This setting may prevent you from taking full advantage of the Website.
We may use third parties, such as Google Analytics or other analytics providers, to analyze traffic to our Website. Google Analytics does not create individual profiles for visitors and only collects aggregate data. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google at http://www.google.com/intl/en/analytics/privacyoverview.html.
Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser.
HOW WE USE YOUR INFORMATION
In general, we collect information and Personal Information from you so that we can provide our Website, operate our business, and provide information that you request from us. This includes but is not limited to the following:
- Providing, operating, improving, maintaining, and protecting our Website
- Providing you with technical and other support
- Sending you updates, marketing communications, and other information about Sunflower Therapeutics, our products and services, and our Website
- Sending you notices and alerts
- Conducting research, analytics, and monitor and analyze trends and usage
- Contacting you and respond to your inquiries
- Enhancing or improving user experience, our business, and our Website, including the safety and security thereof
- Personalizing our Website to you
- As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request
- Enforcing contracts, including investigation of potential violations thereof
- Detecting, preventing, or otherwise addressing fraud, security or technical issues
- Protecting against harm to the rights, property or safety of Sunflower Therapeutics, our users, or the public as required or permitted by law
How we share your information
We do not rent or sell your Personal Information.
Like most companies, we share information, including Personal Information, in certain circumstances with third parties through the operation of our Website and our business. Below we explain when that happens with Personal Information.
SERVICE PROVIDERS
We may transfer Personal Information to third parties for the purpose of providing the Website or operating our business. For example, we may transfer your Personal Information to third-party service providers to assist with providing the Website, and to communicate with you about current or future products and services.
REQUIRED TRANSFERS
We may also transfer your Personal Information to third parties under the following circumstances: (i) to comply with a legal requirement, law, subpoena, judicial proceeding, court order, governmental request, or legal process; (ii) to investigate a possible crime, such as fraud or identity theft; (iii) in connection with the sale, purchase, merger, asset sale, financing, reorganization, liquidation or dissolution of Sunflower Therapeutics, including the evaluation thereof; (iv) when we believe it is necessary to protect the rights, property, or safety of Sunflower Therapeutics or other persons, or (v) as otherwise required or permitted by law, including any contractual obligations of Sunflower Therapeutics.
AS DIRECTED BY YOU AND WITH YOUR CONSENT
Except as otherwise provided in this Privacy Policy, we share Personal Information with companies, organizations or individuals outside of Sunflower Therapeutics only at your direction or when we have your consent to do so.
International Transfer
Our Website is hosted in and operated from the United States. If you use our Website from other countries with laws governing data collection and use that may differ from United States law, then please note that by sending an email or other communication containing Personal Information or by providing Personal Information through our Website, you are voluntarily transferring your Personal Information outside of those regions to the United States.
Residents of the European Economic Area, Switzerland or the United Kingdom
Residents of the EEA, Switzerland, and the United Kingdom have additional privacy rights. Information on these rights is provided in our supplemental European Economic Area, Switzerland and United Kingdom Resident Privacy Notice below.
This European Economic Area (EEA), United Kingdom (UK) and Switzerland Resident Privacy Notice supplements the information contained in our Privacy Policy and applies to residents of the European Economic Area (EEA), the United Kingdom (UK) and Switzerland. It contains additional information required by the EU General Data Protection Regulation (“GDPR”) and the UK and Swiss equivalents. These provisions, which should be read together with the statements in the main Privacy Policy, explain our practices with regard to data privacy in the EEA, UK and Switzerland.
| Jodie Crowley Chief Peold & Operations Officerprivacy@sunflowertx.com |
Sunflower Therapeutics, PBC
200 Boston Avenue, Suite G-500 Phone: 781-539-8100 We have appointed the following entity as our legal representative for purposes of the GDPR: Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Sunflower Therapeutics PBC 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 |
| Purposes of the processing | The purposes of the processing are described in the section of the main Privacy Policy entitled Information We Collect [link to section]. |
| Lawful basis for the processing | Our legal basis for processing personal data is described in the main Privacy Policy and will depend on the personal data concerned and the specific context in which we collect it. Generally, we process personal data on the basis that the processing is necessary for purposes of our legitimate interest in conducting our business in a manner typical in the US biotechnology industry, having taken into account any risks to your fundamental rights and freedoms (including your right to privacy).
We also may process personal data on other bases permitted by the GDPR, the UK Data Protection Act 2018 and other applicable laws, such as to fulfill a contract with you, or when the processing is necessary for us to comply with our legal obligations. |
| The legitimate interests of the controller or third party, where applicable | Our specific legitimate interests, such as responding to your requests, comments and questions, providing you updates about Sunflower Therapeutics and our products and services, and providing you with the Website, are described in the section of the main Privacy Policy entitled Information We Collect [link to section]. |
| The categories of personal data concerned | The categories of personal data that we process are described in the section of the main Privacy Policy entitled Information We Collect [link to section]. |
| The recipients or categories of recipients of the personal data | The potential recipients of the personal data that we collect via the Website are described in the section of the main Privacy Policy entitled How We Share your Information [link to section]. |
| Information regarding the transfers of personal data outside of the European Economic Area (EEA), Switzerland and the United Kingdom (UK) | Sunflower Therapeutics, PBC. is headquartered in the U.S. and the Website is hosted in the U.S. The laws of the U.S. have not been deemed by the European Commission, the United Kingdom or Switzerland to provide an adequate level of protection to personal data.
When you provide your personal data to us, including via the Website or when you contact us by email, you are providing your personal data directly to the U.S. Before you provide your personal data to us, including via the Website, we request your explicit consent to the transfer of your personal data to the U.S. When you email us, the fact that you have chosen to email us knowing that we are located in the U.S. will be understood to constitute your explicit consent to the transfer of the personal data in your email (including your email address) to the U.S. Regardless of the differences in U.S. and European privacy laws, we safeguard your personal data as described in our main Privacy Policy and this section. If we transfer your personal data to a third party, we require the third party to commit contractually to process your personal data only in ways that are consistent with our main Privacy Policy and this supplemental notice. |
| The period for which the personal data will be stored, or the criteria for determining the retention period | How long we retain personal data varies according to the type of data in question, the purpose for which it is used, and applicable data retention and record-keeping requirements. We delete personal data within a reasonable period after we no longer need to use it for the purpose for which it was collected or for any subsequent purpose that is compatible with the original purpose. This does not affect your right to request that we delete your personal data before the end of its retention period. We may archive personal data (which means storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures. |
| Your rights to access, correct, restrict or delete your personal data and object to processing | You have the right to request access to your personal data, to have your personal data corrected, restricted or deleted, the right to data portability, and to object to our processing of your personal data. Your rights may be subject to various limitations under the GDPR. If you wish to exercise any of these rights, or if you have any concerns about our processing of your personal data, please contact us by emailing us at privacy@sunflowertx.com |
| The right to lodge a complaint with a supervisory authority | You have the right to file a complaint concerning our processing of your personal data with your national (or in some countries, regional) data protection authority. The EU Commission has a list here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
See www.ico.org.uk for information about contacting the UK Information Commissioner’s Office. See www.edoeb.admin.ch/edoeb/en/home.html for information about contacting the Swiss Federal Data Protection and Information Commissioner. |
Controlling Cookies
If you are visiting our Website from the EEA. UK, or Switzerland, then we do not set non-essential cookies unless you accept all cookies on the “cookie banner” via our cookie management tool that launches when you land on our Website.
You can learn about how you can adjust your browser’s settings to limit or disable non-essential cookies and other tracking technologies by visiting the section above. Strictly necessary cookies cannot be disabled.
Children’s privacy
Our Website is not intended for use by children under the age of 13 and we do not knowingly collect Personal Information from children under the age of 13 in connection with the Website.
Opting out
If you no longer wish to receive our marketing and promotional communications, you may opt-out by following the instructions included in each communication.
How Do We Protect Your Information
The security of your Personal Information is important to us. We use reasonable administrative, physical, and technical safeguards to secure the Personal Information you share with us. Despite these safeguards and our additional efforts to secure your information, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your Personal Information.
Third-party websites
The Website may contain hyperlinks to websites operated by third parties, which may include social media features, such as social media buttons or links. We provide such hyperlinks for your reference and convenience only. We do not control such websites and are not responsible for their content or the privacy or other practices of such websites. It is up to you to read and fully understand their privacy policies. Our inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators. If you are submitting information to any such third-party through our Website, you should review and understand that party’s applicable policies, including their privacy policies, before providing your information to the third-party.
Changes to our Privacy Policy
We reserve the right to amend this policy at any time without any prior notice to you. Each time you use our Website the current version of this Privacy Policy will apply. When you use our Website, you should check the date of this Privacy Policy (which appears at the top of the Privacy Policy) and review any changes since the last version.
Questions
If you have any questions about this Privacy Policy or our privacy practices, please contact us at:
privacy@sunflowertx.com