This Privacy Policy sets forth the practices of Viracta Therapeutics, Inc. (“Viracta”, “we”, “us” or “our”), and our subsidiaries and affiliates, regarding the collection, use and disclosure of your personal information in connection with our websites (the “Sites”), and our clinical trials (together with the Sites, the “Services”). This Privacy Policy also describes the rights and choices you have with respect to your personal information.
This Privacy Policy does not apply to any information that may be collected by third parties that may link to our Sites. Please read this entire Privacy Policy before using our Services or submitting information to Viracta. Viracta may provide additional privacy notices to individuals at the time we collect their data. For example, we provide a specific privacy notice to clinical trial participants that describes our privacy practices in connection with conducting clinical trials. This type of an “in-time” notice will govern how we may process the information you provide at that time. For example, our privacy practices in connection with clinical trials are governed by applicable clinical trial protocols.
By using our Services, you agree to the terms of this Privacy Policy.
Individuals located in California should read the important information available below.
Personal information we collect
Whose personal information we collect
We collect personal information about the following types of individuals: clinical trial participants, patients, patients’ family members, caregivers, or advocates, physicians and other health care professionals, clinical trial investigators, researchers, pharmacists, users of our Sites, and other individuals who interact directly with Viracta or our service providers or business partners.
How we collect personal information
We collect personal information:
- Directly from you, such as when you contact us
- Through the Sites
- From healthcare professionals
- From hospitals, clinics and other healthcare providers
- 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 and other public forums (including adverse event information or product quality complaints)
Types of personal information we collect
The types of personal information we collect and share depend on the nature of the relationship you have with us and the requirements of applicable laws. We may collect:
- Health and medical information. This includes medical insurance details, information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history, and medications you may take, including the dosage, timing, and frequency) that we collect in connection with managing clinical trials, conducting research, providing patient support programs, managing compassionate use and expanded access programs, and tracking adverse event reports.
- Contact information. Personal and business contact information and preferences such as name, job title, employer name, email address, mailing address, phone number, and emergency contact information.
- Demographic information. Such information includes date of birth, age, gender, marital status, and information regarding any parents or legal guardians.
- Professional credentials. Educational and professional history, certifications, and institutional affiliations
- Payment-related information. This includes information we need to pay for professional services that individuals may provide to us (such as tax identification number and financial account information).
- Professional activity information. If you are a health care professional, we collect information about the programs and activities in which you have participated, your prescribing of our products, and the agreements you have executed with us.
- Digital information. This may include your photograph, social media handle, or digital or electronic signature
- Publicly available information. This may include comments you make online describing support for and experience with our products.
- Correspondence. This refers to other information you provide to us in emails, on phone calls, in market research surveys, or in other correspondence with us or our service providers or business partners.
We may combine other publicly available information, such as information related to the organization for which you work, with the personal information that you provide us.
Cookies and other information automatically collected
While you are using the Sites, we automatically log information provided to us by you, your computer or mobile devices, and your activity over time on the Sites, such as:
- Device data including your IP address (a number assigned to your computer when you use the Internet) your device’s operating system, your Internet service provider and location, browser type and language, your unique device ID (persistent/non-persistent), hardware type, and the website you visited before browsing to our Sites; and
- Online activity data that is collected automatically (such as information about the Site content you access) and information about the date, time and duration of your visit to our Sites.
We also collect information about your use of our site through cookies and similar technology. Cookies contain certain information that a website can then use to make communication between your browser and this site more efficient, such as by tracking site navigation and personal preferences involving dynamic site content. To enable Viracta to provide customized and personalized services, we may use cookies to store and sometimes track information about you.
Do Not Track signals
Some web browsers offer a “Do Not Track” function that can send a signal to websites regarding the user’s privacy preferences. Our Sites do not respond to such signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
How this information is used
We may use your personal information in a variety of ways, including the following:
To operate the Sites:
- To operate, maintain, enhance and provide all features of the Sites and our business, to provide services and information that you request, and to respond to comments and questions.
- To personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the site, and provide customized content and information.
- To monitor and analyze the effectiveness of content on the Sites, monitor aggregate site usage metrics such as total number of visitors and pages viewed, and track other usage of this site.
To communicate with you:
- To contact you for administrative or other business purposes, and to send information that you have requested.
- To send marketing communications, including updates on promotions and events, relating to our Services and products and services offered by third parties we work with.
To provide the Services:
- To manage access to our products, including where access is limited by law to licensed physicians.
- To pay for services that physicians, researchers, and other individuals may provide to us.
- To develop new products, services, features, and functionality.
To perform and administer clinical trials, research, and product-improvement activities:
We may use your personal information when necessary to facilitate our clinical trials, research, studies, and related activities that support product improvement, including:
- To staff and manage clinical trials, including by recruiting investigators and participants.
- To track and respond to safety and product quality concerns (including product recalls).
- To support public health initiatives, symposia, conferences, and scientific, educational, and volunteer events.
- To facilitate medication adherence programs.
- To define and manage appropriate patient engagement activities and patient support programs (including to provide co-pay and other financial assistance where available).
- To identify and engage thought leaders and external experts.
- To award scholarships and research grants.
- To attribute authorship to academic and promotional materials.
To comply with law:
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
To comply with regulatory monitoring and reporting obligations:
We use your personal information as we believe necessary or appropriate to comply with regulatory monitoring and reporting obligations, such as those related to adverse events, product complaints, patient safety, and financial disclosures.
To create anonymous data for analytics:
We may conduct research on users’ demographics, interests, and behavior based upon information you provide during use of our website. We may combine your information with information collected from other individuals to produce anonymous, aggregated statistical information that will not include personally identifiable information. We may use this aggregated information for our business purposes. We may also share this anonymous, aggregated information with third parties, or allow third parties to collect anonymous, aggregated information through our website. We do not have total control over these third parties or which methods they may use to collect information.
For compliance, fraud prevention, and safety
We use your personal information as we believe necessary or appropriate to:
- Enforce the terms and conditions that govern the Services;
- Protect our rights, privacy, safety or property, and/or that of you or others; and
- Protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Other uses:
We also may use your information as may be described in a notice to you at the time the information is collected, or in any other manner to which you consent.
How we share your personal information
Affiliates
We may disclose your information to our affiliates or subsidiaries for purposes consistent with this Privacy Policy.
Service providers
We may employ third-party companies and individuals to perform services on our behalf, including:
- Contract research organizations that conduct clinical trials
- Data storage and analytics providers
- Customer service (including our medical information line) and patient support providers (including for product quality and adverse event reporting, patient co-pay assistance, medicine intake adherence programs, etc.)
- Product recall administration
- Technology services and support (including email and web hosting providers, marketing and advertising technology providers, email and text communications providers, and mobile app developers)
- Event planning and travel organizations that help facilitate Viracta programs
- Payment, shipping, and fulfillment service providers
These third parties may use your information only as directed by Viracta and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
Healthcare professionals and organizations
We may share your personal information with health care professionals, researchers, institutions, academics, public health organizations, and publishers for purposes consistent with this Privacy Policy.
Business partners
We may disclose your personal information to partners with whom we jointly develop products or services, in connection with the development and promotion of such products or services. We will ask for your consent before disclosing your information to our business partners where required by applicable law.
Analytics and advertising partners
When we use third-party cookies and other tracking tools, we may disclose your personal information to those third-party companies to help us analyze use of our Sites and advertise our Services.
Professional advisors
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
Compliance with laws and law enforcement, protection, and safety
We may disclose your personal information to comply with any court order, law, or legal process; to enforce this Privacy Policy, our Terms & Conditions, or other agreements; if we believe disclosure is necessary or appropriate to protect the integrity, security, safety, or rights of Viracta or any other person; or if you consent to such disclosure.
Business transfer
Viracta may, in the future, sell or otherwise transfer some or all of its assets, including your personal information, to an affiliate or to a third party in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization, sale of assets, or in the event of bankruptcy. We will make reasonable efforts to require the recipient to honor this Privacy Policy.
Additional program terms
In some situations, Viracta 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. We will honor these additional terms with respect to your information and thus, strongly recommend you review the additional terms prior to participating in any programs.
Storage and transfer of personal information
Viracta, or in some cases our agents or service providers, may store your personal information in an electronic database. We and our agents may also exchange such information with each other or with you over the internet or over intranet systems for the purposes of processing the data, mailing information to you in response to your request, or otherwise carrying out the Services.
We use reasonable efforts to protect the confidentiality of your personal information. However, there is always some risk involved when submitting information over the internet, and we cannot guarantee that our website is 100% safe from illegal tampering or “hacking.”
Information choices
Changes to your personal information
If you become aware that the personal information we maintain about you is inaccurate, incomplete, misleading, irrelevant or out of date, you may contact us.
Opt out of marketing
You may opt out of marketing-related emails by clicking the “Unsubscribe” link at the bottom of each such email. You may continue to receive service-related and other non-marketing emails.
Testimonials
If you gave us consent to post a testimonial on our Sites, but wish to update or delete the testimonial, please contact us.
Choosing not to share your personal information
Where we are required by law to collect your personal information, or where we need your personal information in order to provide you with our Services, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Services and may need to terminate our relationship with you. We will tell you what information you must provide to us by designating it as required when we request the information or through other appropriate means.
Links to other sites
Viracta Services may contain links to third-party websites that we believe may offer useful information. We are not responsible for the privacy practices or content of these other websites. We encourage you to review the privacy policies of these third-party websites.
Children’s policy
The Sites are not intended or designed to attract children under 13 years of age, and we do not knowingly collect information about children under age 13 in the United States through the Sites. If we learn that a child under age 13 has provided personal information without a parent or guardian’s consent, we will delete such information from our active databases.
International data transfers
Viracta is headquartered in the United States and may have affiliates and service providers in other countries. Your personal information may be transferred to the United States or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
Acceptance of terms
By using this website and voluntarily providing your personally identifiable information to us, you consent to the collection and use of such personally identifiable information as set forth in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not provide us with any information and do not use this site.
Privacy policy updates
We reserve the right, at any time, to modify, alter, or update this policy, and any such modifications, alterations, or updates will be effective upon posting. In the event we modify this Privacy Policy, your continued use of the Services will signify your acceptance of the modified Privacy Policy.
Contact us
Please contact us regarding this Privacy Policy or our privacy practices at:
Viracta Therapeutics, Inc.
2533 S. Coast Hwy 101, Suite 210
Cardiff, CA 92007
Email: [email protected]
This Privacy Policy was last updated February 22, 2021.
Notice to California Residents
The information provided in this section applies only to California residents.
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal information, and of the rights and choices we offer California residents regarding our handling of the personal information.
This notice does not apply to the information we collect in connection with clinical trials, or to any health or medical information we collect that is otherwise governed by California’s Confidentiality of Medical Information Act or the Health Insurance Portability and Accountability Act of 1996. This notice also does not apply to information related to our business contacts (including healthcare providers).
CALIFORNIA RESIDENTS’ PRIVACY RIGHTS
The CCPA grants California residents the following rights.
- You can request information about how we have collected, used and shared and used your Personal Information during the past 12 months.
- Access. You can request a copy of the personal information that we maintain about you.
- Deletion. You can ask us to delete the personal information that we collected or maintain about you.
You are entitled to exercise the rights described above free from discrimination. Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
- HOW TO SUBMIT A REQUEST
- To request access to or deletion of personal information:
- Email: [email protected]
- Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
- Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.
