Privacy Policy

Last updated: June 15, 2021

Introduction

Vincerx Pharma, Inc. (“Vincerx Pharma,” “we,” or “us”) is committed to respecting your online privacy.  This Privacy Policy (“Policy”) describes how Vincerx Pharma collects, uses, and shares (i.e., “processes”) the information, including Personal Information, we receive in connection with the use of our website at www.vincerx.com (the “Website”).

The term “Personal Information” means any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier, or one or more factors specific to you.

Vincerx Pharma is the controller and is responsible for the Personal Information processed in connection with the use of the Website.

Please read this Policy carefully.  By using or accessing the Website, or by providing Personal Information to us on or through the Website, you acknowledge that you have read, understand, and agree to the terms and conditions of this Policy.  If you do not agree, your choice is not to use the Website.

How to Contact Us

We welcome your comments or questions regarding this Privacy Policy.  Please email us via the “Contact Us” page at [www.vincerx.com/contact-us/] or contact us at the following address:

Vincerx Pharma, Inc.
260 Sheridan Avenue, Suite 400
Palo Alto, CA 94306

You can also contact our Data Protection Officer at dpo@vincerx.com

Information We May Collect From You

We may collect Personal Information from you in a variety of ways, including when you provide it to us voluntarily, through automated data collection technologies like cookies, or by receiving it from other sources.  The following sections list the type of information we may collect under each mechanism.

Information that you provide us voluntarily.

You may provide us Personal Information voluntarily when you:

  • Contact us. This occurs, for instance, when you correspond with us by phone, email, or otherwise; when you contact us through the Website, (g., by using the Website email request function); or when you provide us with feedback or report a problem with the Website.  The information you give us may include your name, email address, phone number, physical address, or other Personal Information you provide to us in your communications with us.
  • Request or opt in to receive materials. Some portions of the Website allow you to voluntarily provide us with Personal Information when you “opt in” to receive email alerts (“Materials”).  When subscribing to our Materials, we will process your email address to send you periodic emails regarding quotes, SEC Filings, events, news and weekly summaries.

Information we collect automatically.

We and our third party service providers may use cookies and other automatic data collection technologies to collect information from you as you use the Website, including information about your online activities over time and across third party websites or other online services.

See our Cookie Notice at [https://vincerx.com/cookie-policy/] for more information about the automatic data collection technologies we use and the choices you have for opting out.

How We Use Your Information

We may process Personal Information for the purposes set out in this Policy only where we have a valid legal ground for doing so under applicable data protection law.  The legal ground will depend on the purpose for which we process your Personal Information.

We will process your Personal Information to respond to your inquiries or other communications. We may also share with our Processors (as defined under the GDPR), business partners, and other third parties anonymous data in aggregated form about Website visitors. For example, we might share that the Website users are “x” percent PC users and “y” percent Macintosh users. We have the right to use Anonymous Information for any purpose and in any manner. “Anonymous Information” means information that is not associated with or linked to your Personal Information; Anonymous Information does not, by itself, permit the identification of individual persons. Anonymous Information includes non-personally identifiable data we create from Personal Information by excluding information that makes such data personally identifiable.

If you are based in the European Economic Area (“EEA”) and we collect your Personal Information on our own behalf, we will only process your Personal Information, including sharing it with third parties, for a purpose described above if: (i) you have provided your consent, which can be withdrawn at any time; (ii) the processing is necessary for the performance of a contract to which you are a party; (iii) we are required by law; (iv) it is required to protect your vital interests or those of another person; or (iv) the processing is necessary for the purposes of our legitimate commercial interests, except where such interests are overridden by your rights and interests.

Job Applications

We also publish job advertisements on our website. When you apply for a vacancy at Vincerx, we will collect and process your personal data as a job applicant. This may include your name, address, email address, position of interest, details of your qualifications, skills, experience and employment history and any other information in your application you choose to share with us.
We kindly request that you only submit personal data about yourself in your job application or CV or other relevant material you choose to provide to us, to the extent such information is relevant for the specific position you are applying for.
If your application is unsuccessful, we will hold your data for a period of six months after the end of the relevant recruitment process. This is necessary for the burden of proof in the event of a legal claim. We will delete your data after this period of time. If your application is successful, personal data gathered during the recruitment process will be transferred to your Human Resources file and retained during your employment

How We Share Your Information

We may share information that is not your Personal Information without restriction, including aggregate information about visitors to the Website and information that does not identify any individual.

We may share your Personal Information for the purposes described in this Policy:

  • With our affiliates;
  • With our service providers who assist us with the Website or otherwise perform support services for us;
  • To another business entity in the event of a merger, restructuring, acquisition, any other sale or transfer of our assets or liabilities, or any change in ownership control;
  • To anyone with your consent; and
  • If we have a good faith belief that disclosure is necessary, to: (1) comply with the law or with legal process served on us; (2) protect and defend the rights or property of us or our users; (3) act in an emergency to protect someone’s safety; or (4) investigate any violation or potential violation of the law, this Policy, or any other agreement between you and Vincerx Pharma.

International Transfers

Vincerx Pharma is headquartered in the United States.  The information you provide to us or that we obtain as a result of your use of the Website is collected in your country and subsequently transferred to the United States or to another country in which we have facilities or our affiliates operate or in which we engage service providers or other third parties.

We will not transfer Personal Information relating to individuals within the EEA, to third parties located outside of the EEA without ensuring adequate protection under European law.  Where a third party is located in a country not recognized by the EU Commission as ensuring an adequate level of protection, we will take appropriate steps, such as implementing standard contractual clauses recognized by the EU Commission, to safeguard your Personal Information.

By allowing us to collect personal information about you, you consent to such transfer and processing of your personal information.

Your Information Choices

Communication opt-outs

If you receive Materials or other communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us using the information in the How to Contact Us section above.

Should you opt-out of receiving future mailings, we may share your email address with our Processors to ensure that you no longer receive further communications from the Processors.  Despite your indicated email preferences, we may send you notices of updates to our Privacy Policy or other terms for the Website.

Cookie opt-outs

Please see our Cookie Notice at [https://vincerx.com/cookie-policy/] for information about cookie opt-outs.

Do Not Track disclosure

The Website does not respond to “do not track” signals at this time.  For a description of “Do Not Track” information for browsers and mobile devices, and information about opt out programs that third party advertising companies participate in, please visit https://allaboutdnt.com/.

Your California privacy rights

For California residents only.  Under California’s “Shine the Light Act,” California residents are permitted to opt-out of the disclosure of Personal Information to third parties for their marketing use.  Please contact us using the information in the How to Contact Us section above to opt-out of the sharing of your Personal Information with third parties for marketing purposes.

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

Your Data Protection Rights

You have the right to ask us not to process your Personal Information for marketing purposes.  We will usually inform you (before collecting your Personal Information) if we intend to use your Personal Information for such purposes or if we intend to disclose your information to any third party for such purposes.  You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Information.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or by contacting us using the How to Contact Us section above.

Under European data protection law, in certain circumstances, you have the right to:

  • Request access to any Personal Information we hold about you as well as related information, including the recipients or categories of recipients to whom the Personal Information has been shared;
  • Obtain without undue delay the correction of any inaccurate Personal Information we hold about you;
  • Request Personal Information held about you to be deleted, provided the Personal Information is not required by Vincerx Pharma for compliance with a legal obligation under European or Member State law or for the establishment, exercise, or defense of a legal claim;
  • Prevent or restrict processing of your Personal Information, except to the extent processing is required for the establishment, exercise or defense of legal claims; and
  • Request transfer of Personal Information directly to a third party where this is technically feasible.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

In addition, where you believe that Vincerx Pharma has not complied with its obligations under this Policy or European law, you have the right to make a complaint to your local Data Protection Authority or the North-Rhine-Westphalian Data Protection Authority.

You can exercise any of these rights by contacting us using the How to Contact Us section above.

Additional Information

Data Retention

We will store your Personal Information, in a form which permits us to identify you, for no longer than is necessary for the purpose for which the Personal Information is processed.   We may retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, have an ongoing legitimate business need to do so and enforce our agreements and rights. When we have no ongoing legitimate business need to process your personal information, we will delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.  Consistent with these requirements, we will try to delete your Personal Information quickly upon request.

Data storage and security

We store all your Personal Information on our secure servers.  We have commercially reasonable security measures in place to help protect against loss, misuse, and alteration of your Personal Information in our possession.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure.  Therefore, we cannot guarantee the absolute security of information transmitted to the Website; any transmission is at your own risk.  Vincerx Pharma will contractually require each Processor or other third-party with whom it shares Personal Information to use reasonable measures to protect that Personal Information.  However, we cannot monitor these Processors and other third parties to ensure that they comply.

Links to third party websites

We may create links to third party websites, including in the form of widgets (e.g., social share buttons) that enable users to easily share information on another platform, such as a social media platform.  The third parties that own these widgets may have access to information about your browsing on the Website where these widgets are placed.

We do not evaluate and are not responsible for the privacy practices or content of third party websites, including the websites of our affiliates.  We encourage you to review the privacy policies of each link to ensure that you are comfortable with their privacy practices.

Privacy of children

The Website is not intended for children under 16 years of age and we do not knowingly collect Personal Information from children under 16.  If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under the age of 16, please contact us using the How to Contact Us section above.

Changes to This Privacy Policy

We may make changes to this Policy from time to time.  Should we make a material change to our information collection and processing practices, we will provide you with advance notice by communicating such changes through our Website (e.g., by posting a banner notice).  Additionally,  we will revise the “Last Updated” date found as part of this Policy.  Any changes will only be applied to information collected on a going forward basis.  Your continued use of the Website following the posting of any notice regarding such changes to this Policy indicates your acceptance of the new terms.

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