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 EU and the Data Protection Act of 2018 in the 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 US. 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 US.

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.

Choices and 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.

General Data Protection Regulation (GDPR) – EU Representative

Pursuant to Article 27 of the General Data Protection Regulation (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 General Data Protection Regulation (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.

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 June 15, 2023