Last Updated: May 25, 2022
Version number: 2.0
Iovance Biotherapeutics, Inc. and its subsidiaries (collectively “Iovance”, “we” or “us”), value your privacy. This privacy notice (“Notice”) describes how Iovance collects, uses, retains, and shares Personal Information about you, your household, or your device (collectively “you”), whether obtained online or offline. This Notice does not apply to job applicants, employees, clinical or commercial site health personnel, and clinical trial participants, which are covered by separate privacy notices provided by other means. This Notice also does not apply to information collected through third-party websites or links provided to social media sites. This Notice tells you about your rights and choices with respect to your Personal Information, and how to reach us if you have any questions about our practices.
We recognize that privacy is an ongoing responsibility, and so we may update this Notice from time to time. Please review this page periodically to remain informed. If the changes are material, we will provide notice of changes in a clear and conspicuous manner. Your use of the website and the processing of your Personal Information is governed by this Notice.
TABLE OF CONTENTS
You can jump to a particular section by clicking on the headings below:
PERSONAL INFORMATION WE COLLECT
Some of the information we collect can directly or indirectly identify you. This is called your Personal Information. We collect this information in a variety of ways through our websites, social media pages, online, and offline. These include:
Information you provide us:
- Contact information (such as first and last name, mailing address, email address, telephone number, professional affiliation);
- Demographic or geographic information (such as gender, date of birth, age, zip code);
- For healthcare professionals: information obtained from a w-9, information obtained from public sources or databases, professional affiliations, and credentials (such as resume or CV or information from these documents, Medical License Number, specialty, skills) contact information, educational and professional history and publications;
- Data about your medical condition(s);
- Your photograph, video, voice recording, or digital electronic signature;
- Your social media handle;
- Other information you choose to provide to us that will be used in accordance with this Notice.
Information collected automatically:
- Usage information about your interaction with our website and online content (such as pages visited, frequency of access, time spent on each page, browser used, internet address of the site that directed you to our website and referring website details).
- Location information about your location, which may be determined through your IP address. You can adjust your consent to providing location information in the browser settings.
- Device information about the device you use to access the website, such as hardware model, operating system, browser, and device preferences.
Information from Other Sources: We may also receive information about you from other sources, including third parties, such as our business partners, our affiliates, publicly available sources, or social networks in which you participate.
HOW WE COLLECT YOUR PERSONAL INFORMATION
Iovance limits the collection and use of personal information to what is necessary to fulfill the purpose for which it was collected. Examples of these purposes are:
- signing up for a newsletter;
- registering for an event or program;
- signing up for informational or marketing material;
- directly contacting us or providing us your information;
- visiting our websites or offices;
- using our services;
- interacting with you on social media or via email;
- responding to inquiries; or
- other means
If you submit Personal Information relating to others, you represent to Iovance that you have the authority to do so.
HOW WE USE YOUR PERSONAL INFORMATION
- To respond to your requests;
- To improve our level of service;
- To provide our products and services to you;
- To promote our products and services;
- To provide you information when you request it, or when we believe it may interest you;
- To invite you to provide your views on our products and services, participate in research or attend events;
- To complete transactions;
- To report any product adverse events that you notify us about;
- To perform analytics and understand your preferences;
- To provide access where required to our sites and facilities;
- For our own administrative and quality assurance purposes; and
- For other purposes that may be detailed on our website which will be described at the time the information is collected, and as permitted by applicable law.
HOW LONG YOUR PERSONAL INFORMATION IS KEPT
We keep your Personal Information for as long as needed or legally permitted for the purpose(s) for which it was obtained, unless otherwise provided in agreements between you and Iovance or as required or authorized by law.
DATA INTEGRITY AND SECURITY
The confidentiality of Personal Information transmitted over the Internet or method of electronic storage cannot be guaranteed; therefore, when submitting Personal Information to Iovance online, you must weigh both the benefits and the risks. While Iovance cares about your privacy and has implemented reasonable steps to protect your Personal Information from unauthorized access, disclosure, alteration or destruction, we cannot guarantee the security of your Personal Information. Iovance collects Personal Information in compliance with its intended use and it is accurate, complete, and current.
UPDATING AND ACCESSING YOUR DATA
We encourage you to update the Personal Information you provide Iovance periodically. Additionally, Iovance complies with laws and regulations relating to your rights to amend your Personal Information in our files when permissible. All requests to update or access your Personal Information will be subject to verification of your identity to protect you. If you wish to access or correct your Personal Information, you can contact Iovance Privacy at email@example.com and we will respond to your request.
You may unsubscribe from our marketing emails at any time by following the instructions included in those emails. Any requests to opt-out of future communications from Iovance, or to opt-out of a particular Iovance program, should be directed to Iovance using the contact method indicated in the marketing email.
CHILDREN’S ONLINE PRIVACY
Iovance’s website is not directed at children under 13. If you are under 13, do not use or provide any Personal Information to Iovance. If we learn that we have collected or received Personal Information from a child under 13 without parental consent, or if you become aware that we may have such information, alert us immediately at firstname.lastname@example.org so that we can delete this information. For more information about protecting the privacy of children online in the United States under the Children’s Online Privacy Protection Act (“COPPA”), please visit: http://www.ftc.gov/ogc/coppa1.htm.
Minors under 18 years of age may have the Personal Information that they provide to us deleted by sending an email requesting deletion to email@example.com. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.
SUPPLEMENTAL TERMS FOR SPECIFIC GEOGRAPHIC AREAS
The following provisions are applicable to persons from the geographic areas specifically named below. These provisions supersede any conflicting general statements made above. To the extent that any Personal Information is sent outside of an individual’s country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
Iovance endeavors to obtain assurances from its service providers and affiliates that they will safeguard Personal Information consistent with this Notice, such as by providing at least the same level of protection as is required by Iovance’s privacy principles set out here. Where Iovance has knowledge that a service provider or affiliate is using or disclosing Personal Information in a manner contrary to this Notice, Iovance will take appropriate steps to prevent or stop the use or disclosure.
EUROPEAN ECONOMIC AREA (EEA), SWITZERLAND AND THE UNITED KINGDOM (UK)
To the extent Iovance receives or processes Personal Information directly from an individual located in the EEA or UK via its websites, or via electronic or regular mail from such individual, the following additional principles and disclosures shall apply:
- For the processing of Personal Information relating to the European Economic Area, Iovance has assigned a data protection officer (DPO) and a data protection representative (DPR) responsible for overseeing our compliance with EU data protection law, and the UK data protection law.
|EEA||Jeremy Bodefirstname.lastname@example.org||DPO Consultancy B.V.||email@example.com|
Reitscheweg 37, 5232 BX ‘s-Hertogenbosch, The Netherlands
|UK||Jeremy Bodefirstname.lastname@example.org||DPO Consultancy Ltd.||email@example.com|
19 The Square, Retford
Nottinghamshire, DN 22 6DQ
- The processing of your Personal Information is intended for the following purposes: for legitimate interest or the performance of a contract in accordance with Art. 6 (1) (b) and (f) the EU General Data Protection Regulation (EU) 2016/679 (“GDPR”);
- The categories of recipients of your Personal Information are Iovance employees and consultants;
- You have the following rights:
- Right to Access. You have the right to request access to the Personal Information you provided us;
- Right to Deletion. You have the right to request deletion of your Personal Information that you provided us, subject to certain exceptions.
- Right to Rectification. You have the right to rectify inaccuracies about the Personal Information you provided us;
- Right to Restrict. You have the right to restrict processing concerning your Personal Information;
- Right to be Informed. You have the right to know what Personal Information is collected about you, why, who is collecting it, how long it will be kept, how it is shared and how to file a complaint;
- Right to Object. You have the right to object to the processing of your Personal Information;
- Right to Portability. You have the right to receive your Personal Information in a manner that is structured and in a standard format and potentially transmitted to another party; and/or
- Withdrawal of Consent. If consent was obtained, you have the right to withdraw your consent for the processing of Personal Information.
You may exercise these rights free of charge unless the request is unfounded, excessive, or otherwise unreasonable, for instance, because it is repetitive. In some situations, we may refuse to act or may impose limitations on your rights, as permitted by law.
You will be required to provide your Personal Information so that Iovance can respond to the inquiry and so that we may verify your identity.
For questions or complaints concerning the processing of your Personal Information, you can email our DPO at firstname.lastname@example.org. In many countries, you may have the right to lodge a complaint with the appropriate data protection authority in your country. You can find the relevant name and contact details under http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Transfers of your Personal Information may be made to entities located outside the European Economic Area, including entities located in the United States, for processing consistent with the purposes above. Pursuant to Article 46 of the GDPR, Iovance will implement appropriate contractual measures (including standard data protection clauses, a copy of which you can obtain by contacting) to ensure that the relevant Iovance companies and third parties outside the EEA provide an adequate level of protection to your Personal Information as set out in this Privacy Statement and as required by applicable law.
The California Consumer Privacy Act (CCPA) grants certain rights to California residents. To the extent the CCPA applies to our processing of your personal information, you would be entitled to the following rights:
- Right to Access. You have the right to request the Personal Information we have collected, used, disclosed, and sold about you.
- Right to Deletion. You have the right to request deletion of your personal information, subject to certain exceptions.
- Right to Opt-Out of Selling. You have the right to opt-out of the sale of your personal information to third parties. Iovance does not have actual knowledge that it sells personal information of minors under the age of sixteen (16).
- Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights under the CCPA.
If you are a California resident and want to submit a request exercising your rights, please contact us at email@example.com or by mail at the address listed below. You must provide us with sufficient information that allows us to reasonably verify who you are and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are unable to verify your identity with the information provided, we may ask you for additional pieces of information. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual. Please note that we are not obligated to respond to more than two access requests for the same individual’s Personal Information within a 12-month period.
California law also permits California residents to request certain information about our disclosure of Personal Information to third parties for their own direct marketing purposes during the preceding calendar year. As discussed elsewhere in this Notice, we do not currently share the Personal Information of California residents with third parties for their own direct marketing purposes. However, if you have further questions about our privacy practices and compliance with California law, please contact us as explained below.
If you have questions or comments about our privacy practices or this Notice or to request this Notice in another form, contact us at:
Iovance Biotherapeutics, Inc.
Attn: Privacy Office
825 Industrial Road, Suite 400, San Carlos, California