Who We Are

The website phenotherapeutics.com is operated by Pheno Therapeutics Limited so that Pheno Therapeutics Limited may contact you with information and/or in response to enquiries that you make via the website.

Where we use “we”, “our” or “us” in this privacy notice, we mean Pheno Therapeutics Limited unless we say otherwise. Where we use “our site” in this privacy notice, we mean phenotherapeutics.com.

Who we are

The Information We Collect About You

Each time you visit our site, we may automatically collect information about you and the device you are using, including:

• Information about which pages you visit and which resources you use on our site
• Information about how you got to our site
• Your internet protocol address known as your IP address which is used to connect your device to the internet
• Your device’s operating system and platform
• The type and version of the browser you are using
• Browser plug-in types and versions which extend the functionality of your browser, for example Pinterest, Evernote and Adblock
• MAC addresses which are used as network addresses for Wi-Fi and Ethernet
• Traffic data, which is aggregated information about the number of visitors, sessions, users and page visits to our site
• Location data
• Time zone setting
• Weblogs

Information Provided Directly From You

We also collect any information you provide to us directly by contacting us by any of the methods referred to on our website for example:

• Your name
• Your email address

Please see our Cookie Notice for details of the cookies we use on our site.

Where do we get your information from?

We collect the information you provide to us directly by contacting us directly through one of the methods referred to on our website, for example by email (e.g. to info@phenotherapeutics.com) or telephone.

We also collect information directly from your device. We use cookies to collect some of this information. Please see our Cookie Notice for details of the information we collect through our site.

Why do we need your information?

We need the information we collect automatically about your visit to our site to:

• Administer our site
• Improve our site to ensure that content is presented in the most effective manner
• Analyse how visitors use our site (including behaviour patterns and the tracking of visits across multiple devices)
• Improve your online experience

We need the information you provide by contacting us directly through one of the methods referred to on our website and / or by filling in any of the forms to:

• Contact you about those services on our site in which you have expressed an interest
• Contact you to respond to any enquiries or other correspondence from you including (but not limited to) any enquiries or correspondence from you relating to clinical trials
• Process an application you have made for a job opening via our website

You do not have to give us any information or confirm that the information we have obtained from other sources is correct.

Who do we share your information with?

We may share your personal data with third parties where this is required by law, where it is necessary to perform a contract with you, or where we have another legitimate interest in doing so.

All of these third parties are required to take appropriate security measures to protect your personal information in line with our policies. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Our service providers

We may share your personal data with our third party service providers that perform services and functions at our direction and on our behalf. Our service providers are IT service providers, our recruitment service providers, our lawyers and our cloud storage providers. We rely on service providers in order to effectively operate our business.

Third party companies associated with a sale or acquisition of, or investment in, the business

In the event that we sell or buy any business or assets, we may share your personal data to the prospective seller or buyer of such business, assets or shareholdings.

In the event that we seek to obtain additional investment, we may share your personal data to prospective investor(s).

Other third parties

We may need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process. We may disclose your personal data if we are required by law to do so or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or another legal process.

Transferring information outside the EU

We may transfer some personal information we collect about you to the following countries outside the EU:  the United States and Switzerland, for example where this is necessary for the purposes of our commercial relationships with our investors, to send limited personal data to board members and directors who are not based in the EU, and for cloud storage provision.

There is an adequacy decision by the European Commission in respect of Switzerland. This means that Switzerland is deemed to provide an adequate level of protection for your personal information. There is not an adequacy decision by the European Commission in respect of the United States. This means that the United States is not deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information that is transferred to the United States does receive an adequate level of protection we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection, namely ensuring that the third parties have joined the EU-US Privacy Shield, or by agreeing standard contractual clauses with the third partiesation is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection, namely standard contractual clauses.

In addition, we seek to obtain copies or access to the third parties’ data protection policies where possible and only supply the minimum amount of personal data required for the purposes of the activities mentioned above.

If you require further information about these protective measures, you can request it from the Data Privacy Manager.

Google Analytics

We use Google Analytics to collect details of how you use our site. We do this to help us analyse how visitors use our site (including behaviour patterns and the tracking of visits across multiple devices). Google Analytics doesn’t collect information that identifies a visitor to our site.

All the information that is collected is anonymous and is only used to improve how our site works. We do not allow Google to make any attempt to establish the identities of any users of our site. Please see our Cookie Notice for more details about Google Analytics.

Where is your information stored?

Your information is generally stored on servers and filing systems in the European Economic Area which includes the UK, but it may also be stored in or accessed from countries outside the EEA. Where this may happen, we always make sure that there are appropriate safeguards in place, such as the standard contract clauses, binding corporate rules or the EU-US Privacy Shield, to guarantee that your information – and your rights – are protected to the same high standard as under UK law.

Our site may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy notices and cookie notices and we do not accept any responsibility or liability for those notices or your use of those websites. Please check these policies before you submit any personal data to these websites.

Unfortunately sending information via the internet is not totally secure. Although we do our best to protect your information, we cannot guarantee the security of any information you transmit to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

How long do we keep your information for?

We only keep your information for as long as we need it.

If you provide information directly to us by making enquiries with us/sending correspondence to us through one of the methods referred to on our website, we will keep your information for no more than 3 months from the date of the last communication between us.

If you have made an application for a job opening via our website, we will keep your information for a period of 12 months after we have communicated to you our decision about whether to appoint you.

After this period, we will securely destroy your personal information in accordance with our data retention policy.

We keep your information for this long so that we can:

• deal with any issues or concerns that you may have about how we handled your personal data
• bring or defend any legal claims

Further information in relation to the way we handle the personal data of job applicants is set out in our Candidate Privacy Notice, a copy of which is available on request at the postal address above or by email to info@phenotherapeutics.com.

Do we carry out profiling and automated decision making?

We use Google Analytics to collect details of how you use our site, as well as anonymous data that you enter into our forms. We do this to help us analyse how visitors use our site (including behaviour patterns and the tracking of visits across multiple devices), administer our site and manage your account. Google Analytics doesn’t collect information that identifies a visitor to our site.

All the information that is collected is anonymous and is only used to improve how our site works. We do not allow Google to make any attempt to establish the identities of any users of our site. Please see our Cookie Notice for more details about Google Analytics.

We do not carry out any other profiling or automated decision-making in respect of the information we automatically collect about you when you visit our site.

What rights do you have?

Under the data protection rules, you have several rights in respect of your information, which include the right to:

• access your information
• withdraw your consent to the processing of your information at any time
• ask us to make changes to the information we hold about you to make sure that it is accurate and up to date
• delete or erase your information (sometimes called the right to be forgotten)
• stop or restrict our processing of your information
• object to our processing your information
• not be subject to automated decision-making and
• request the transfer of some of the information we hold about you (known as data portability).

If you would like to exercise any of your rights, please contact us at info@phenotherapeutics.com or in writing to the Data Privacy Manager at the Company’s postal address above. Please note that an archive copy of any information provided to us may be retained by us for our records and for audit purposes.

You have the right to request a copy of the information we hold about you by sending your request in writing to us at the above address.

Making a complaint

If you have any questions, concerns or complaints about the way Pheno Therapeutics processes your personal information, please contact us at the postal address above or at info@phenotherapeutics.com.

If you are not happy with the way we have handled your complaint or are still concerned about our handling of your personal information, you have a right to take your complaint to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF and www.ico.org.uk.

Changes to this notice

We will regularly review this notice and keep it updated to make sure that the information we provide you with is accurate and up to date. We will retain previous policies which can be requested form us at the postal address above or at info@phenotherapeutics.com.

This notice was last reviewed and updated in July 2022.