Privacy Notice

Privacy Notice

This Privacy Notice explains the practices that Wugen Inc. (“Wugen”, “we”, “us”) follows in connection with the personal data that we collect through this website, when you contact us directly, automatically through our systems, and through our research or services.

Information We Collect About You

We collect different types of information, including:

• For the purposes of the work that Wugen performs and the regulations that Wugen needs to comply with, we collect personal data that relates to an identified or identifiable individual, such as a name, email, mailing address, phone number, or any information related to an individual’s health for the purpose of healthcare research.
• For purposes of the services that Wugen provides to the Clinical Site (defined below), we collect personal data from the Clinical Site investigator and personnel, including name, address, curriculum vitae, training records, financial disclosures, and any correspondence between the Clinical Site and the investor or personnel related to their interest in the clinical trial.

For the purpose of ensuring our website is working properly and optimally, we use necessary cookies that do not collect personal data or track your activity on the website.

How We Collect and Process Your Personal Data

Requests for Contact

We collect personal data provided directly by individuals during direct communication with Wugen through web forms, emails, or by phone. We collect name, email address and the reason for the communication.

We use your personal data to acknowledge and respond to your request.

Clinical Research

For the purpose of our research, we do not collect your personal data directly. Your personal data is collected through the partners (“Clinical Site”) that manage the clinical trials that we sponsor. They collect your personal data as a participant of the clinical trial or as Clinical Site investigator or personnel involved in the clinical trial.

The patient data that we obtain and use from the Clinical Site is pseudonymized and managed through an identifier that we cannot link back to you directly. Only the Clinical Site that collected your personal data is able to link it with the identifier they provide to us. The data we obtain from the Clinical Site and process, with your consent, includes:

• An identifier to track future data against
• Data concerning your health and how you are responding to the clinical trial
• Genetic data

We use your personal data to review the outcomes of the clinical trial.

The data related to the Clinical Site investigator and personnel is used to verify qualifications, satisfy documentation requirements for work performed related to the clinical trial, to verify any financial conflict of interest and for other administrative purposes related to the work performed related to the clinical trial.

Our Legal Basis for Processing Your Personal Data

In order to comply with different privacy and data protection regulations around the world and specifically to comply with the General Data Protection Regulation (“GDPR”) in the European Union (“EU”) and the Data Protection Act of 2018 (“UK GDPR”) in the UK (“UK”), we require to provide a legal basis for the processing of your personal data.

Wugen will not process your personal data unless we have a legal justification to do so. Wugen will only process your personal data if:

• We or the Clinical Sites we partner with, have obtained your explicit consent prior to the processing of your personal data;
• If we need your personal data to perform a contractual obligation to which you are a party or where you have requested us to complete a contractual request;
• If we need to process your personal data to fulfill our legal and regulatory obligations;
• If we have a legitimate interest that will not put your fundamental rights and freedoms at risk.
  
  

Disclosure of Your Information

Wugen will only disclose your personal data to the following parties under specific circumstances:

• To Wugen personnel, if required, to fulfill your request;
• To our subsidiaries and affiliates;
• To service providers that support our systems or support the activities of the clinical trial, including the Clinical Sites that hold personal data about patients and personnel;
• To enforce or apply our terms of service or contracts;
• To law enforcement, regulatory bodies or courts, when we are required to do so under applicable laws and regulations;
• In connection with the sale or reorganization of all or part of our business, as permitted by applicable law;
• If in the future we need to disclose your personal data to any other party, we will inform you in advance and will request your consent to disclose if necessary.

Security

We maintain appropriate safeguards and take reasonable steps to protect your personal data, ensure that we limit its use and that we disclose it only to the parties that have a legitimate reason to have access to it.

We ensure that all the parties that we disclose your personal data to, internal and external to Wugen, have contractual obligations in place to protect the security and the confidentiality of your personal data at the same level that Wugen does.

Data Transfers and Storage

Your personal data will be transferred to systems that reside in the United States (“U.S.”). The data will be protected at all times and pseudonymized in some cases to ensure that the risks to your privacy are minimized.

We have implemented Standard Contractual Clauses for parties that reside in the EU and International Data Transfer Agreements for parties that reside in the UK and that will transfer personal data to Wugen in the U.S.

Wugen complies with the requirements of the EU-U.S. Data Privacy Framework (“DPF”) and the UK Extension to the EU-U.S. DPF. For more information regarding our adherence to these frameworks, refer to the Data Privacy Framework Compliance section.

Data Privacy Framework Compliance

Wugen complies with the EU-U.S. Data Privacy Framework program (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce.  Wugen has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

The Federal Trade Commission has jurisdiction over Wugen’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

Data Privacy Framework Complaint Resolution Mechanism

In compliance with the EU-U.S. Data Privacy Framework Principles and the UK Extension to the EU-U.S. DPF, Wugen commits to resolve DPF Principles-related complaints about your privacy and our collection and use of your personal information transferred to the United States pursuant to the DPF Principles.  European Union and United Kingdom individuals with DPF inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact Wugen at privacy@wugen.com.

Wugen has further committed to refer unresolved privacy complaints under the DPF Principles concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to an independent dispute resolution mechanism based in the US, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your complaint involves human resources data transferred to the United States from the European Union, or the United Kingdom, as applicable in the context of the employment relationship, and Wugen does not address is satisfactorily, Wugen commits to cooperate with the panel established by the EU Data Protection Authorities (“DPA Panel”), and the UK Information Commissioner’s Office (“ICO”), as applicable and to comply with the advice given by the DPA Panel or ICO, as applicable with regard to such human resources data. To pursue an unresolved human resources compliant, you should contact the state or national data protection or labor authority in the appropriate jurisdiction. Complaints related to human resources data should not be address to the BBB National Programs.

In compliance with the EU-U.S. Data Privacy Framework Principles and the UK Extension to the EU-U.S. DPF, Wugen commits to cooperate and comply respectively with the advice of the panel established by the EU Data Protection Authorities (“DPAs”), the UK Information Commissioner’s Office (“ICO”) and the Gibraltar Regulatory Authority (“GRA”) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

Onward Transfer to Third Parties

Wugen’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Wugen remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Wugen proves that it is not responsible for the event giving rise to the damage.

Choices and Rights Over Your Personal Data

Pursuant to the Data Privacy Frameworks, EU and UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to privacy@wugen.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@wugen.com.

Other Rights Over Your Personal Data

Subject to any exceptions, you have the right to request access to, update or delete your personal data.

You also have the right to request restriction of or object to the processing of your personal data. And you have the right to request to have your data provided to you in an electronic format if you desire to have a copy of it.

On each particular case, we will inform you of the consequences of your request and if there are any exemptions to honoring your requests based on legal, contractual, or other requirements.

During a clinical trial your rights to access, update or delete your pseudonymized personal data may be limited as permitted by law. Specifically, we need to process your data in specific ways in order to maintain the reliability and integrity of the study for reasons of public interest in public health and for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.

How To Exercise Your Personal Data Rights

To submit any request about your personal data you may contact us via email at privacy@wugen.com.

Children Under the Age of 13

We do not knowingly collect personal data from children under 13. Our website is not intended for children under 13 years of age. No one under age 13 may provide any information to us through our website. If you are under 13, do not use or provide any information to us through our website.  If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@wugen.com.

GDPR – EU Representative

Pursuant to Article 27 of the GDPR, Wugen has appointed European Data Protection Office (“EDPO”) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:

• Using EDPO’s online request form: https://edpo.com/gdpr-data-request/
• Writing to EDPO at Regus Paris- Champs Elysées, 12/14 rond-point des Champs Elysées, Paris, 75008, France.

UK GDPR – UK Representative

Pursuant to Article 27 of the UK GDPR, Wugen has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR by:

• Using EDPO UK’s online request form: https://edpo.com/uk-gdpr-data-request/
• Writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

EU/UK Individuals – Right to Lodge a Complaint with a Supervisory Authority

If you reside in the EU or the UK and want to lodge a complaint with a Supervisory Authority (“Data Protection Authority”) you may do so in the country where you reside, where you work or where you may have experienced an issue with the processing of your personal data.

Changes to Our Privacy Notice

It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat personal data, we will notify you through a notice on the website home page. The date the Privacy Notice was last revised is identified at the bottom of the page. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes.

Data Retention

Wugen will not retain your contact information after your request has been fulfilled.

Wugen and the Clinical Sites that we partner with for the purpose of clinical trials will retain your personal data for as long as necessary for the purpose of research, and to comply with legal and regulatory obligations.

California Residents Notice

Wugen does not collect, process, disclose or sell your personal data for marketing purposes or for Wugen’s business benefit.

The personal data collected, processed and disclosed for the purpose of clinical trials is not subject to the California Consumer Privacy Act. However, we welcome your contact requests by reaching out to privacy@wugen.com if you wish to verify if Wugen holds any personal data about you outside of the scope of clinical trials.

How to Contact Us

If you have any further questions regarding the personal data that Wugen or any of our partners collect and process or if you have feedback regarding this Privacy Notice, you may contact us at privacy@wugen.com.

This privacy notice was last reviewed on December 9, 2024.