Cytel EEA Privacy Disclosures
Last Updated: 10/03/2018
The following additional EEA privacy disclosures (the “Disclosures”) supplement the Cytel Privacy Notice. These Disclosures apply only to how we collect, use and share the Personal Data of individuals located in the EEA that we gather through our Online Platforms as a Data Controller and that are within the scope of the European Union’s General Data Protection Regulation (“GDPR”) (collectively, the “Processing”). The “Online Platforms” include the websites, mobile apps, and other digital properties that are owned and operated by Cytel that link to these Disclosures as well as certain third-party databases. “We” or “Cytel” mean Cytel Inc. and our family of companies, including our affiliates and subsidiaries.
If you have any questions about these Disclosures or our data practices, please contact us using the options provided below.
Please read these Disclosures carefully. By using our Online Platforms, you consent to the data practices and other terms set forth in these Disclosures.
How We Collect, Use and Retain Personal Data
When we use the term “Personal Data,” we mean data that can be used to identify you as an individual person. We collect several categories of Personal Data as part of the Processing, including data you provide, data collected automatically from your device, and data we obtain from third party sources. We use and share this Personal Data for the purposes described below, including as described under Additional Uses of Personal Data.
We rely on separate and overlapping bases to process your Personal Data lawfully. By way of example only, it may be necessary for us to process your Personal Data in certain ways in order to process a transaction you have requested or otherwise in accordance with a contract between us, or in certain cases we may process your Personal Data where necessary to further our legitimate interests, where those legitimate interests are not overridden by your rights and interests.
How We Share and Disclose Personal Data
We share your Personal Data with third parties only in the ways described in these Disclosures. We may share your Personal Data within our family of companies, with service providers and business partners, in connection with business transfers and to comply with the law, protect health and safety and enforce our legal rights.
International Data Transfers
Cytel may transfer your Personal Data within our family of companies and/or to the third parties discussed above. Your Personal Data may be transferred to, stored, and processed in a country other than the one in which it was collected. We may transfer your Personal Data outside the European Economic Area (“EEA”) and when we do so, we rely on appropriate or suitable safeguards recognized under data protection laws.
We are committed to protecting the privacy of children. Our Online Platforms are not directed to, and we do not intend to or knowingly collect or solicit Personal Data online from children under the age of 18. If you are under the age of 18, do not provide us with any Personal Data.
We process all personal data in line with your rights, in each case to the extent required by and in accordance with applicable law (including in accordance with any applicable time limits and fee requirements).
Links to Third Party Sites and Social Media
The Online Platforms may include links to websites and digital services operated by third parties. These Disclosures do not apply to, and we are not responsible for the content, privacy notices or data practices of third parties that collect your data. We encourage you to review the privacy notices for those third parties to learn about their data practices.
Updates to the Disclosures
These Disclosures are subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by prominently posting notice of the changes on the Online Platforms and updating the effective date above. The updated Disclosures will be effective thirty (30) calendar days following the posting. You can determine when these Disclosures were last revised by checking the Last Updated date at the start of the Disclosures.
Managing Communication Preferences
If you have opted in to our marketing communications (or where permitted by law, if you have provided us with your contact information), we may send you email messages, direct mail offers, or other communications regarding products or services depending on the method of communication selected. You may ask us not to do so when you access our websites or mobile applications, or change your preferences by updating any accounts you have with us. At any time, you may elect to discontinue receiving commercial messages from us by submitting an opt-out request to the contact information below or by following the unsubscribe instructions in the form of the communication you received, as described below.
If you have any questions, comments, requests or concerns about these Disclosures or other
Att: Privacy Officer
675 Massachusetts Avenue
Cambridge, MA 02139
Our data protection officer is Joanne Murphy.
Phone: (+ 1) 617 987 9486
For purposes of the General Data Protection Regulation: Our controller entities in Europe are Cytel Statistical Services and Software UK Limited, Cytel France SARL, and Cytel Spain SL.
Cytel France SARL
63, Avenue des Champs Elysées
75008 Paris, France
T + 33 1 84 79 61 70
Cytel Spain SL
Ronda Universitat 33, 1° 1
08007 Barcelona, Spain
T +34 660 010 852
Cytel Statistical Services and Software UK Limited
Hamilton House, Mabledon Place
London, Greater London WC1H 9BB
T +44 203 911 8349