Updated July 25, 2023
Welcome to the website (the “Site”) of PYRAMID BIOSCIENCES, INC. (“PYRAMID,” “we,” “us,” or “our”). Through the Site, PYRAMID provides information about our company and our investment in and development and commercialization of drug therapies (such information, together with the Site, the “Activities”).
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, pharmacist, contractors, consultants, job applicants, volunteers, visitors to our offices, and other individuals who interact directly with PYRAMID or its service providers or business partners, including users of websites and mobile applications.
Types of Personal Data We Collect
The personal data we collect is determined by the nature of the relationship you have with PYRAMID and the requirements of applicable laws. The types of personal data we may 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.
- Device data, such as your computer’s or mobile device’s IP address, unique identifiers (including identifiers used for advertising purposes), and general location information such as city, state or geographic area.
- Online activity data through cookies and other automated means, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
- Your photograph, social media handle or digital or electronic signature.
- If you are a visitor to an PYRAMID 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).
We collect personal data:
- Directly from individuals as part of our research or recruitment activities
- Automatically through our websites and mobile device 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
Cookies and Other Automated Information Collection
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.
You may restrict or block web browser cookies on your device, through your browser settings (usually found under “privacy” or “ads”). Web browsers may offer users of our websites the ability to disable receiving certain types of cookies, however, if cookies are disabled, some features or functionality of our websites may not function correctly. You can visit www.aboutcookies.org/how-to-control-cookies for information about cookies and how to disable them.
Similarly, some browsers offer a “do not track” or “DNT” option which sends a signal to websites visited indicating a visitor’s tracking preference. This site does not currently respond to such signals, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators. The third-party providers we use may or may not response to a DNT signal.
How We Use 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 we offer, activities we engage in and for 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).
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.
Legal Basis for Processing Data
In some cases, PYRAMID 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, PYRAMID 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 PYRAMID 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 activities we engage in.
PYRAMID’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.
PYRAMID may also process personal data as specifically permitted by applicable legal requirements, such as laws and regulations that authorize PYRAMID to process personal data for purposes of clinical trials.
Sharing and Disclosure of Personal Data
- PYRAMID affiliates and research partners.
- Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors 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 PYRAMID 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.
- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users, or the public, or (v) protect against legal liability.
International data transfers
Personal Data Access Rights
Individuals can exercise the following rights in relation to the personal data that we may have collected about you. Please note that if the exercise of these rights limits our ability to process personal data, we may not be able to provide our products to individuals who exercise these rights, or to otherwise engage with such individuals going forward.
We reserve the right to verify the identity of the 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.
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 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. I 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.
Note about “Sales” : PYRAMID does not “sell” personal data as most people would typically understand that term. To request further information about this, you can do so by contacting us using the details provided in the Contact Us section below.
To exercise any of the rights described herein, please contact us using the details provided in the Contact Us section below. When submitting a request to exercise 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 may need to verify your identity before processing your request, which may require us to request additional personal data from you.
Our activities are not directed at children who are under the age of 16. PYRAMID does not knowingly collect Personal Data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Data to PYRAMID please contact us and we will endeavor to delete that information from our databases.
Links To Other Websites
You engage in the Activities at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, we cannot guarantee that the measures we maintain will ensure the security of personal data. E-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to PYRAMID via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the site, or Third-party websites.
PYRAMID BIOSCIENCES, INC., 1200 US Highway 22 East, Suite 2000-2310, Bridgewater, NJ 08807, USA