1. Privacy Statement
The terms “you” and “your” refer to each individual who is a source of Personally Identifiable Information to Onconova, including (i) individuals who transact business with Onconova, such as our customers, vendors, contracting parties, and other users of our goods or services (“External Users”), (ii) employees of Onconova and its affiliates, including its affiliates and subsidiaries outside of the United States, as well as applicants for employment by Onconova or its affiliates (“Internal Users”); and (iii) casual visitors to our Website, who do not participate in or receive Onconova services (“Site Visitors”). For convenience, we use the term “User” to refer collectively to our External Users, Internal Users, and Site Visitors.
2. US-EU Safe Harbor Program
Onconova complies with the EU Safe Harbor framework regarding the collection, use and retention of data from the European Union, as set forth by the United States Department of Commerce at http://www.export.gov/safeharbor. Onconova, where applicable, complies with the EU Data Protection Directive and its implementation in Member States where it has legal entities.
3. General Information on Privacy: Definitions
The term “Personally Identifiable Information” as used in this Policy refers to two categories of personal data: General Personally Identifiable Information and Sensitive Personally Identifiable Information.
• General Personally Identifiable Information is defined as first and last name, birth date, gender, e-mail address, mailing address, profession, education, or professional affiliations used to identify you.
• Sensitive Personally Identifiable Information is defined as all other levels of personal information including, but not limited to, religion, race, health status, political opinion, sexual orientation, income, social security number, credit card numbers, order history, or prescribing habits. Together, we refer to General Personally Identifiable Information and Sensitive Identifiable Information as “Personally Identifiable Information.” Onconova will collect and use only as much Personally Identifiable Information as is (i) required by law or (ii) necessary to fulfill the purpose for which the Information is collected, as such purposes are detailed in this Policy.
When you provide Personally Identifiable Information to Onconova, we will tell you why the information is being requested and for what purpose it will be used. For example, we may collect and use Personally Identifiable Information to provide you with information regarding our products or services, to bill you for products and services you request, to market products and services which we think may be of interest to you, or to communicate with you for other purposes.
Personally Identifiable Information collected by Onconova and its affiliates in the course of conducting business may be transmitted to Onconova’s United States offices for use, maintenance and processing, as permitted by applicable laws. We will always provide you the opportunity to (i) opt-out of our use of General Personal Information and (ii) opt-in for our use of Sensitive Personal Information, as discussed in Section 7 (Choice).
4.1. Personal Data – External Users
If you conduct business with Onconova, it is likely that you will provide Personally Identifiable Information to us in connection with this business relationship. We use Personally Identifiable Information provided by our External Users to fulfill business transactions in which the parties are engaged, to monitor and ensure performance of each party’s obligations, and for other business purposes (“Business Contact Information”). We also may use this Personally Identifiable Information to notify our External Users of business and other developments that concern Onconova or that concern the Users’ business and other interests (“Business Updates”). If an External User chooses to withhold Business Contact Information that we request for the purposes stated above, it may not be possible for us to undertake, or continue a business relationship with that User. In contrast, all External Users are entitled to opt-out of use of their Personally Identifiable Information for Business Updates, in accordance with Section 7 (Choice).
4.2. Personal Data – Internal Users
4.3. Personal Data – Site Visitors
Most of our services do not require any form of registration, allowing a Site Visitor to visit the Website without telling us who he or she is. However, some services may require registration. When you register with us, you may need to complete certain fields (some are required and some are optional), as well as choose a user name and password. In these situations, should you choose to withhold Personally Identifiable Information requested by us, it may not be possible for you to gain access to certain parts of the site and for us to respond to your query.
4.4. Use and Disclosure of Information
Subject to the provisions of Section 8 (Onward Transfer), Onconova will not sell, share, or otherwise distribute Personally Identifiable Information to third parties outside of Onconova.
5. Spamming; E-mail Contacts
Onconova does not condone “spamming.” “Spamming” is sending unsolicited e-mails, usually of a commercial nature, in large numbers and repeatedly to individuals with whom the sender has had no previous contact or who have declined to receive such communications.
In contrast, where Onconova believes that certain product, health, or other information is of importance to you, and you have previously consented to our use of your name and address for such mailings (by, for example, providing us information under this Policy), Onconova reserves the right to inform you by e-mail. We will always provide you the opportunity to opt-out of receiving such contact. If you would like to read more about how to opt-out, please follow the directions given below in Section 7 (Choice) of this document.
6. Use of Anonymous Information; Cookies and Other Tracking Systems
In the course of providing services, operating this Website, and otherwise conducting our business, we will compile and use anonymous information. Anonymous information is information in a form that does not allow a third party to identify you. Anonymous information might include, for example, the fact that an unidentified Site Visitor viewed certain pages on our Website, or performed certain searches on the Website. Anonymous information might also include survey responses and other feedback that Users provide to us, where this information has been de-identified to prevent disclosure of the User who provided the information. We use anonymous information, and engage consultants to assist us in using this information, to improve our goods and services, and the features and content of the Website, to compile and analyze aggregate statistics about our Users, and to engage in related business, marketing, and research activities, on the commitment that any such uses will not identify you.
When you visit the Website, we do not collect any information from which a third party may be able to personally identify you, such as your name, address, e-mail address or telephone numbers, without your express consent. To compile anonymous information concerning use of the Website, Onconova may request or provide your browser with “cookies.” Cookies, by themselves, cannot be used to discover the specific identity of the user. A cookie is a small piece of information that is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie or to reject cookies and this will enable you to decide if you want to accept it or not. Onconova may not permit you to access certain Web pages within the Website in the event your browser does not accept a cookie request.
On occasion, we may use Internet tags (also known as action tags, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by-1 GIFs) in combination with cookies and may deploy these tags through a third-party advertising partner. These tags are on different pages of the Website to measure visitors’ responses to the Website and the effectiveness of our advertising campaigns (including how many times a page is opened and the information viewed). These Internet tags may provide certain demographic information, but again, will never provide Personally Identifiable Information. If you would like more information about Web tags and cookies associated with on-line advertising or to opt-out of third-party collection of anonymous information, please visit the Network Advertising Initiative Website at www.networkadvertising.org.
Onconova will not use your Personally Identifiable Information in ways unrelated to the ones described above without first notifying you and offering a choice. This choice may be offered at the bottom of our on-line or off-line communications to you as well as on many of our web registration pages. If you would like to exercise your choice you can always send your request to Onconova Therapeutics, Inc., ATTN: Privacy, 375 Pheasant Run, Newtown, PA 18940 USA. See Section 16 (Contact Us).
7.1. Opt-Out of Use of General Personal Information
Onconova will provide you the opportunity to let us know if you wish to opt-out at any time from our use of your General Personal Information, including certain or all contacts from Onconova, and we will do everything we can to honor such requests. Opting-out of certain uses may impact our relationship with you, as further outlined in Sections 4.1 through 4.3.
7.2. Opt-In for Use of Sensitive Personal Information
In the event that Onconova would like to use your Sensitive Personal Information for a purpose other than the purpose for which it was originally collected, we will provide you the opportunity to “opt-in” or decide whether you agree to such use of your Sensitive Personal Information. Without your explicit consent, we will not use your Sensitive Personal Information for a purpose other than the purpose for which it was collected.
8. Onward Transfer
Onconova does not sell, rent or lease your Personally Identifiable Information to others. Unless we have your permission or are required by law, we only share your Personally Identifiable Information with other Onconova affiliates or our contractors who are acting on our behalf for the uses described above. Our contractors are obligated to keep Personally Identifiable Information confidential and may not use it for any purpose other than to carry out the services they are performing for Onconova. Additionally, we ensure that our affiliates’ privacy policies are at least as protective of your information as this Policy.
Subject to your permission or as permitted by applicable law, the Personally Identifiable Information that you provide us may be transferred across state or country borders to consolidate data storage, to simplify information management, or to permit centralized decision-making and analysis.
To the extent permitted by applicable laws, we may disclose Personally Identifiable Information to government authorities or third parties pursuant to a legal request, subpoena, or other legal process. We may also use or disclose your information as permitted by law to protect the rights or property of Onconova, our customers, the Website, or our Users. To the extent that US discovery laws conflict with foreign national data protection and/or privacy laws, we will comply with orders of and direction from the court or other regulatory authority that has jurisdiction to resolve such conflict.
Onconova is committed to ensuring the security of your Personally Identifiable Information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of Personally Identifiable Information, we have put in place appropriate physical, electronic and organizational measures to safeguard and secure this Information. Onconova employees are required to acknowledge that they understand and will abide by our policies with respect to the confidentiality of Personally Identifiable Information. Moreover, we provide access to our databases containing Personally Identifiable Information on a need-to-know basis only.
Please understand, however, that this information should not be construed in any way as giving business, legal, or other advice, or warranting as fail-proof, the security of information submitted to or collected by Onconova. Due to the nature of Internet communications and evolving technologies, we cannot provide, and disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
10. Access and Data Integrity
Onconova strives to keep your Personally Identifiable Information accurate. We will provide you with reasonable access to Personally Identifiable Information you have provided to Onconova and reasonable ability to review and correct it, or ask for deletion, as applicable. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access or enabling you to make corrections. To access your Personally Identifiable Information, please contact us in accordance with Section 16 (Contact Us).
Individuals who believe their complaints have not been resolved to their satisfaction through Onconova’s internal procedures may contact the data protection authority in their jurisdiction. Onconova is committed to working with national data protection authorities to (i) resolve disputes over Onconova’s privacy practices and (ii) comply with the decisions and orders of these data protection authorities. If you have questions regarding how to contact the data protection authority in your jurisdiction, please contact us in accordance with Section 16 (Contact Us).
The Website is not intended for, or designed to attract, individuals under the age of 18. We do not collect Personally Identifiable Information from any person we actually know is an individual under the age of 18.
Onconova abides by the Children’s Online Privacy Protection Act (COPPA) in the U.S. and respects similar laws designed to protect children found in other countries. For more information on COPPA, go to http://www.ftc.gov/privacy/coppafaqs.shtm.
13. Links to Other Sites
14. Change in Control
Should there be a corporate change in control, through merger, acquisition or bankruptcy, we reserve the right to transfer Personally Identifiable Information collected from you to the new party-in-control of Onconova in the normal course of business, provided such party agrees to comply with this Policy.
16. Contact Us
If you have any questions, concerns or comments about our privacy practices, please contact us at:
Onconova Therapeutics, Inc.
375 Pheasant Run
Newtown, PA 18940