Introduction

This policy explains the terms which apply to users of any web sites operated by, or on behalf, of Cycle (together “Cycle Website”). Cycle Pharmaceuticals Ltd, a company registered in England and Wales with company number 07933058 (“Cycle/We/Us”). Registered office address: Bailey Grundy Barrett Building, Little St. Mary’s Lane, Cambridge, Cambridgeshire, England, CB2 1RR. Cycle is a private limited company acting on behalf of itself and its subsidiaries.

These Terms incorporate the following additional terms and conditions and policies:

By using a Cycle Website, you consent and agree to be bound by and abide by these Terms and Conditions of Use (“Terms”).

  • Your Account
  • Your Use of Cycle Websites
  • Cycle Content
  • Your Content and Feedback
  • Trademarks
  • Copyright
  • Cycle Liability and Warranties
  • Your Indemnities
  • Information about you and your visits to the Cycle Website
  • Transactions concluded through the Cycle Website
  • Links from the Cycle Website
  • Specific Cycle Websites or Product Practices
  • Changes to the Cycle Website
  • Changes to the Terms and Conditions of Use
  • Export
  • General

Your Account

You may register for updates on a Cycle Website (“Updates“) and must do so in accordance with the following terms:

  • You must not provide any false information when registering for Updates or register for Updates for anyone else without their
  • You must provide a valid email
  • You must be at least 18 years old to register for Updates on any Cycle
  • You must not assign or transfer your registration for Updates to another person or third
  • All of the information we collect from you is subject to our Privacy Policy. If you breach these Terms we may contact you directly using the information you have provided during registration for some of the Cycle Websites allow you to adjust your privacy settings. These privacy settings are not transferred between the Cycle

Your Use of a Cycle Website

You agree to use a Cycle Website only for lawful purposes and in accordance with these Terms and any applicable licenses provided with content. For example, you will not use a Cycle Website in a way:

  1. infringes, misappropriates or violates any third party intellectual property rights;
  2. attempts to gain unauthorised access to the Cycle Website, the server on which the Cycle Website is stored, or any server, computer or database connected to the Cycle Website;
  3. attempts to or does modify, adapt, or hack the service or modify another website so as to falsely imply that it is associated with the Cycle Website, Cycle, or any other Cycle product or service;
  4. generates or facilitates sending unsolicited email;
  5. is defamatory, harmful to minors, or pornographic;
  6. contains hate-related or violent content;
  7. contains or distributes any viruses or programming routines intended to damage, surreptitiously intercept or expropriate any system, data or information; or
  8. violates or encourages conduct that would violate any criminal laws, any other applicable laws, or any third-party

We reserve the right to temporarily or permanently suspend, disable, or limit your access to a Cycle Website or remove content. We may report any illegal act to the relevant law enforcement authorities.

Violence towards or abuse of Cycle staff will never be tolerated. This includes behaviour or language, spoken or written, that may cause staff to feel afraid, threatened or abused. Cycle will not tolerate this behaviour in any type of interaction with Cycle staff. Our staff will always try to assist you with any issues you may have, but if you behave in a rude, offensive, abusive or intimidating manner then our staff reserve the right to terminate the interaction with you. We may also report any illegal act to the relevant law enforcement authorities.

Cycle Content

All intellectual property rights (including copyright) in the look and feel of any Cycle Website are owned by Cycle. All intellectual property rights (including copyright) in the content of any Cycle Website are owned by Cycle or its licensors. You agree not to reproduce, duplicate, copy, sell, resell or exploit any portion of any Cycle Website without our express written permission.

When using any Cycle Website, you may be able to access or download certain content provided by: a) Cycle (“Cycle Content“); or b) third party providers (“Third Party Content“).

Any such Cycle Content or Third Party Content is governed by the license that accompanies it. By using or downloading any Cycle Content or Third Party Content, you agree to the applicable license. It is your responsibility to ensure you have proper permission for your use of the content. If you are unclear as to what license applies to any content, it is recommended that you ask the author of the content.

We grant you permission to download the information from the Cycle Website on to a computer and to make one hard copy of the information for reference purposes only.

With respect to material, including but not limited to still images, video footage, audio product or visual representations, press releases, FAQs and other downloads, contained within the Cycle Website, we only grant you permission to download the material for informational and non-commercial personal use. We do not grant you a right for republication, retransmission, reproduction or other use of such material. You must not copy or post the material on any network computer or broadcast it in or on any media.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way or remove the copyright notice from any such copies, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Any of the material on the Cycle Website may be out of date or include omissions, inaccuracies or other errors at any given time, and we are under no obligation to update such material.

Commentary and other materials posted on the Cycle Website site are not intended to amount to advice on which reliance should be placed. We therefore disclaim all liability and responsibility arising from any reliance placed on such materials by any visitor to the Cycle Website, or by anyone who may be informed of any of its contents.

Your Feedback

We would like you to provide any suggestions, comments, feedback, ideas, input or know- how you may have on improving any Cycle Website (“Feedback“). You represent and warrant that any Feedback is not confidential and does not contain any proprietary information which you do not have the right to provide to Cycle. You hereby grant to Cycle a non-exclusive, worldwide, royalty-free license to use, reproduce, distribute, adapt, modify, and publish your Feedback. To provide Feedback please email: marketing@cyclepharma.com.

Trademarks

You may not use any Cycle logo without express prior permission from Cycle. If you wish to receive further information about using a Cycle logo please contact Cycle by email: marketing@cyclepharma.com.

Copyright

Please contact Cycle at the address or email below if:

  • you are a rights holder (or an authorized representative) and you wish to report to Cycle any alleged infringement of your copyright or trademarks; or
  • you wish to report any other unacceptable or inappropriate content, including without limitation any threatening or defamatory behaviour, any indecent, obscene, hateful or offensive

Legal Department

Cycle Pharmaceuticals Ltd Bailey Grundy Barrett Building Little St. Mary’s Lane Cambridge

England CB2 1RR

legal@cyclepharma.com

By notifying Cycle of an alleged infringement you represent, under penalty of perjury that the information in the notification is accurate and that giving false, misleading or inaccurate information may result in civil or criminal liability.

Upon receipt, Cycle will review your notification and decide whether or not further action will be required. Such action may include without limitation, editing or removing the relevant material. Please contact us if you wish to report any abuse of Cycle intellectual property rights by a third party.

Cycle Liability and Warranties

EXCEPT WHERE EXPRESSLY PROVIDED OTHERWISE IN AN AGREEMENT BETWEEN YOU AND US, CYCLE PROVIDES NO WARRANTIES EXPRESS, IMPLIED OR STATUTORY, INCLUDING, WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF MERCHANTABILITY, SATISFACTORY QUALITY, NON INFRINGEMENT OR FITNESS FOR A PARTICULAR PURPOSE UNDER THESE TERMS AND IN RESPECT OF ANY CYCLE, ANY CONTENT PROVIDED ON ANY CYCLE WEBSITE (INCLUDING THIRD PARTY CONTENT), AND/OR ANY SERVICES PROVIDED ON ANY CYCLE WEBSITE. YOU RECOGNIZE THAT THE CURRENT STATE OF TECHNOLOGY DOES NOT ALLOW FOR ERROR-FREE ACCESS TO ANY CYCLE WEBSITES AND INTERRUPTIONS, CRASHES, AND DOWNTIME ARE BEYOND CYCLE’S CONTROL AND MAY OCCUR FROM TIME TO TIME. ALL INFORMATION PROVIDED DIRECTLY ON THE CYCLE WEBSITE OR INDIRECTLY THROUGH THE CYCLE WEBSITE BY HYPERTEXT LINK OR OTHERWISE IS PROVIDED “AS IS” WITHOUT WARRANTY OF ANY KIND.

IF YOU ARE ACCEPTING THESE TERMS ON BEHALF OF A COMPANY OR OTHER LEGAL ENTITY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH ENTITY, ITS AFFILIATES AND ALL USERS WHO ACCESS ANY CYCLE WEBSITE THROUGH YOUR ACCOUNT TO THESE TERMS AND CONDITIONS, IN WHICH CASE THE TERMS “YOU” OR “YOUR” SHALL REFER TO SUCH ENTITY, ITS AFFILIATES AND USERS ASSOCIATED WITH IT. IF YOU DO NOT HAVE SUCH AUTHORITY, OR IF YOU DO NOT AGREE WITH THESE TERMS, YOU MUST NOT ACCEPT THESE TERMS AND MAY NOT USE ANY CYCLE WEBSITE.

IN NO EVENT SHALL WE BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES, OR DAMAGES FOR LOSS OF PROFITS, REVENUE, DATA OR USE, INCURRED BY YOU OR ANY THIRD PARTY, WHETHER IN CONTRACT, TORT OR OTHERWISE, ARISING IN CONNECTION WITH THESE TERMS INCLUDING FROM YOUR ACCESS TO, USE OF, OR RELIANCE UPON INFORMATION OBTAINED FROM OR THROUGH, THE CYCLE WEBSITE AND/OR ANY SERVICES PROVIDED ON THE CYCLE WEBSITE. WE RESERVE THE RIGHT TO MAKE CHANGES, UPDATES OR CORRECTIONS TO THE INFORMATION ON THE CYCLE WEBSITE AT ANY TIME WITHOUT NOTICE.

NOTWITHSTANDING ANYTHING TO THE CONTRARY CONTAINED IN THESE TERMS, THE MAXIMUM LIABILITY OF CYCLE TO YOU IN AGGREGATE FOR ALL CLAIMS MADE AGAINST CYCLE IN CONTRACT, TORT OR OTHERWISE UNDER OR IN CONNECTION WITH THESE TERMS, INCLUDING BUT NOT LIMITED TO THE WEBSITE, YOUR ACCESS TO OR USE OF (OR YOUR FAILURE TO GAIN ACCESS TO OR USE OF) THE SITE, ANY CONTENT PROVIDED ON THE SITE (INCLUDING THIRD PARTY CONTENT), AND/OR ANY SERVICES PROVIDED ON THE SITE, SHALL NOT EXCEED £100,000.

THIS STATEMENT DOES NOT AFFECT ATTEMPT TO EXCLUDE CYCLE’S LIABILITY FOR DEATH OR PERSONAL INJURY ARISING FROM NEGLIGENCE, NOR CYCLE’S LIABILITY FOR FRAUDULENT MISREPRESENTATION OR MISREPRESENTATION AS TO A FUNDAMENTAL MATTER, NOR ANY OTHER LIABILITY WHICH CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

Your Indemnities

You agree to hold harmless and indemnify Cycle from and against any claims, damages, losses, liabilities, costs, and expenses (including reasonable attorney fees) arising out of or due to: (a) direct or indirect use of Your Content, including any claim of alleged infringement or misappropriation of third party rights; (b) your breach of any of the representations and warranties herein; or (c) your violation of any applicable law or regulation.

Information about you and your visits to the Cycle Websites

We process information about you gained from your use of the Cycle Website in accordance with our Privacy Policy and Cookie Policy.

Transactions concluded through Cycle Websites.

Contracts for the supply of goods, services or information formed through the Cycle Website or as a result of visits made by you are governed by Cycle’s terms and conditions notified to you during each individual transaction.

Links from Cycle Websites

Where the Cycle Website contains links to other sites and resources provided by third parties, these links are provided for your information only. We are providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by us of the third party sites and resources. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third party websites, you do so at your own risk.

Links to Cycle Websites

You may not link to Cycle’s Website from your site without obtaining Cycle’s prior written consent.

Changes to the Cycle Website

Access to the Cycle Website is permitted on a temporary basis, and we reserve the right to withdraw or amend the information we provide on the Cycle Website without notice. We will not be liable if for any reason the Cycle Website is unavailable at any time or for any period. From time to time, we may restrict access to some parts of a Cycle Website or an entire Cycle Website.

Export

You will comply with all applicable export and import laws and regulations in your use of any Cycle Website and any content.

You represent that you are not barred from receiving services under U.S. laws or other applicable jurisdiction, including without limitations, the Denied Persons List and the Entity List, and other lists issued by the U.S. Department of Commerce, Bureau of Industry and Security. You represent that you are not located in, under the control of, or a national or resident of any country to which the United States has embargoed goods.

IFPMA Code of Pharmaceutical Marketing Practices

Any content on the Cycle Website has been prepared with reference to the IFPMA Code of Pharmaceutical Marketing Practices. In using the Cycle Website you agree that any concerns you may have regarding the content will be reported to Cycle in the first instance by emailing: marketing@cyclepharma.com. If you remain unsatisfied following Cycle’s response please submit a complaint to the IFPMA, Geneva, Switzerland. Any complaints concerning the Cycle Website’s content which is specific to one country may alternatively be submitted to the pharmaceutical manufacturers association in the country concerned.

General

We cannot guarantee that any Cycle Website will be free from viruses or other harmful material so please update your computer’s virus protection software regularly.

The provisions contained in each clause and sub-clause of these Terms shall be enforceable independently of each of the others and if a provision of these Terms are, or becomes, illegal, invalid or deemed unenforceable by any court or administrative body of competent jurisdiction it shall not affect the legality, validity or enforceability of any other provisions of these Terms. If any of these provisions is so held to be illegal, invalid or unenforceable but would be legal, valid or enforceable if some part of the provision were deleted, the provision in question will apply with such modification as may be necessary to make it legal, valid or enforceable.

Except as expressly provided otherwise in a signed agreement between you and Cycle, these Terms constitute the entire agreement between the parties with respect to the subject matter hereof, and supersede and replace all prior or contemporaneous understandings or agreements, written or oral, regarding the subject matter.

Failure or delay to enforce any provision of these Terms shall not be deemed a waiver of future enforcement of that or any other provision.

These Terms are governed by the laws of England and Wales.

In the event of any dispute arising out of or in connection with these Terms, the parties agree to submit to either the jurisdiction of the English courts or the jurisdiction of your country of residence’s Courts.

Changes to these Terms

We may revise these Terms at any time by amending this page, and where appropriate, by notification on the Cycle Website. You should check this page from time to time to review any changes We have made. Some of the provisions contained in these Terms may also be superseded by provisions or notices published elsewhere on Cycle Websites.

Thank you for visiting Cycle’s site.

GL-0026 Date of Production: October 2019 –  Copyright © 2019 Cycle Pharmaceuticals Ltd. All rights reserved.

Introduction

 Cycle understands the fundamental importance of privacy, data protection, and security. We take your privacy seriously and are committed to safeguarding your personal data.

This Privacy Policy (“Privacy Policy”) informs you how Cycle collects, processes, transfers and protects personal data. Cycle Pharmaceuticals Ltd is a company registered in England and Wales with company number 07933058 (“Cycle/we/us”). Registered office address: Bailey Grundy Barrett Building, Little St.Mary’s Lane, Cambridge, England, CB2 1RR. Cycle is a private limited company acting on behalf of itself and its subsidiaries.

In this Privacy Policy, “personal data” means any information which on its own or combined with other information relates to and identifies (directly or indirectly) a living individual.

Scope

This Privacy Policy applies to all Cycle companies as well as Cycle websites, domains, services, applications, and products.

This Privacy Policy does not apply to third-party applications, websites, products, services or social media platforms that may be accessed through links that we provide to you. These sites are owned and operated independently from us, and they have their own separate privacy and data collection practices. Any personal data that you provide to these websites will be governed by the third party’s own privacy policy. We cannot accept liability for the actions or policies of these independent sites, and we are not responsible for the content or privacy practices of such sites.

Types of Data We Collect and How We Collect It Data you provide

When you interact with us, we collect and process personal data from your online activity, your use of devices, products or services. This data can be used to help you register for updates, deliver products or services to you or improve the way we or our products work with you. This data may include:

  • Update information such as your name, title, date of birth, gender, company, profile photo, email address, mailing address and phone
  • Payment information such as your billing address, credit card, debit card or other payment
  • Other information such as your occupation, employment details, academic institution details and residential

Data we automatically collect 

When you visit a Cycle website we automatically collect and store information about your visit using browser cookies (files which are sent by us to your computer) or similar technology which we can access when you visit a Cycle website in future. For further information regarding our use of cookies please refer to our Cookie Policy.

We also process information when you use the Cycle Website or services. This information includes IP addresses, login information, device IDs, time stamps, authentication records, location information, carrier service used, signal strength, the origin, destination, type and quantity of traffic passed and other operational data.

Data we collect from third parties 

We may receive your personal data from third parties such as social network platforms, partners and other sources. This information is not collected by us but by a third party and is subject to the relevant third party’s own separate privacy and data collection policies. We do not have any control or input on how your personal data is handled by third parties so if you have any questions you should contact the relevant third party for further information about your personal data.

How We Use Personal Data We Collect 

We collect and use personal data about you with your consent to provide, maintain, and develop our products and services and understand how to improve them.

  • provide you with alerts, products, promotions, services, newsletters, invitations and other information about health topics and disease states in accordance with your preferences;
  • respond to correspondence that we receive from you (in particular with regard to a report of an adverse event);
  • provide you with additional information that might be of interest to you;
  • operate our business;
  • improve our services and products;
  • deliver our products and services;
  • process, complete and fulfil your requested transactions;
  • identify you and manage any accounts you hold with us;
  • customize our website and its content to your particular preferences;
  • notify you of any changes to our website or to our services that may affect you;
  • help diagnose problems with the
  • host discussions, blogs and information to encourage knowledge sharing and effective collaboration;
  • investigate and prevent security incidents such as breaches, attacks and hacks;
  • aggregate your information in an anonymised form to generate usage statistics;
  • display content and advertising, including third-party advertising, that we believe might be of interest to you;

Where we process your personal data to provide a product or service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in our legitimate interests to provide products and services and to maintain our relationship with you and to protect our business for example against fraud. We will seek your consent to send you direct marketing.

Process and storage 

We store and process data on servers in the European Economic Area (EEA). However, your personal data may also be transferred to and processed in regions including North America, Africa and Asia Pacific. Laws protecting your personal data may be different to the place where you live. We will take appropriate steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy as well as applicable data protection law.

Sharing and Disclosure 

We will share your personal data with third parties only in the ways set out in this Privacy Policy or set out at the point when the personal data is collected. We consider your personal data to be a vital part of our relationship with you. We do not sell your personal data to third parties, including to third-party advertisers.

Cycle Subsidiaries 

We may share your information across the Cycle corporate group in order to provide, maintain and develop our products and services.

Legal Requirement 

We may use or disclose your personal data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical to do so, we will tell you in advance of such disclosure.

Service Providers and Other Third Parties 

We use a variety of third-party service providers, independent contractors, agencies, approved distributors and consultants to deliver and help us improve our products and services. Service providers may be within or located outside the EEA. We may share your personal data with marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others but only to maintain and improve our products and services.

Data Aggregation and Analytics 

We may collate your personal data you provide to us or we collect and use it anonymously for analytics, benchmarking and to effectively monitor the website and improve your user experience.

Security

We take reasonable steps to safeguard the personal information that you provide to us. You acknowledge that the use of the internet is not entirely secure. For this reason Cycle cannot guarantee the security or integrity of any data transferred over the internet, and the information that you provide to us is at your own risk.

To the extent permitted by law, Cycle may review, scan or analyse communications for fraud prevention, investigation, regulatory compliance, risk assessment, research, product development, and customer support purposes.

We use industry-standard encryption technologies when transferring and receiving personal data, and network access control technology to limit access to the systems on which personal data is stored, and we monitor for possible vulnerabilities and attacks.

If you become aware that there has been a breach in security of any of the personal data that we store or that is stored by our third-party service providers, please contact us via the instructions provided in the Contact Us section below.

Retention 

We will only retain your personal data for as long as necessary for the purpose for which that data was collected and to the extent required by applicable law. When we no longer need personal data, we will remove it from our systems and / or take steps to anonymise it.

Your rights 

You have the following rights (if applicable):

Access 

You have the right to request a copy of the personal data we are processing about you.

Rectification 

You have the right to have incomplete or inaccurate personal data that we process about you rectified.

Deletion 

You have the right to request that we delete personal data that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

Restriction 

You have the right to restrict our processing of your personal data where you believe such data to be inaccurate; our processing is unlawful; or if we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish us to delete it.

Portability

You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal data which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.

Objection 

Where the legal justification for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.

Withdrawing Consent 

If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge such as where you wish to opt out from marketing messages that you receive from us. If you wish to withdraw your consent, please contact us at dataprotectionoffice@cyclepharma.com.

You can make a request to exercise any of these rights in relation to your personal data by sending the request by mail to Data Protection Office of Cycle Pharmaceuticals Ltd, Bailey Grundy Barrett Building, Little St.Mary’s Lane, Cambridge, England, CB2 1RR or email to dataprotectionoffice@cyclepharma.com. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.

Children’s Privacy 

We do not knowingly collect or solicit personal information from anyone under the age of 18 without prior parental or authorized caregiver consent. If you are under 18 please do not attempt to register for the services on our website or send any personal information about yourself to us. To the extent that you are under 18, please have your parent or authorized caregiver register for the services on our website. If we learn that we have collected personal information from a child under age 18 without obtaining prior parental or authorized caregiver consent we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us personal information, please contact us at dataprotectionoffice@cyclepharma.com.

Changes 

We may modify this Privacy Policy at any time. If we make changes to this Privacy Policy then we will post an updated version of this Privacy Policy on our website. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Us 

To contact us, please email dataprotectionoffice@cyclepharma.com or write to us at:

Data Protection Office
Bailey Grundy Barrett Building Little St.Mary’s Lane Cambridge
Cambridgeshire England
CB2 1RR

Complaints 

If you have a complaint about this Privacy Policy or any element of your personal information that we hold then please contact us at the above address. If you are not satisfied, then you have the right to lodge a complaint with your local data protection authority.

If you are based in, or the issue relates to, the UK, you can contact the Information Commissioner’s Office at the following address:

Information Commissioner’s Office Wycliffe House
Water Lane Wilmslow Cheshire England SK9 5AF

Alternatively, you can use an online form via the Information Commissioner’s website (https://ico.org.uk/concerns).

If you are based in, or the issue you would to complain about took place elsewhere in the EEA, please visit this website: (http://ec.europa.eu/newsroom/article29/document.cfm?action=display&doc_id=50061) for a list of local data protection authorities in other EEA countries.

If you are based in, or the issue relates to, the US, you can contact the Federal Trade Commission at the following address:

Federal Trade Commission, Bureau of Consumer Protection, Division of Privacy and Identity Protection
Federal Trade Commission (Headquarters)
600 Pennsylvania Avenue, NW
Washington, DC 20580

Alternatively, you can use an online form via the Federal Trade Commission website (https://www.ftccomplaintassistant.gov/#crnt&panel1-1).

If you are based in, or the issue relates to, Canada, you can contact the Federal Trade Commission at the following address:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Québec
K1A 1H3

Alternatively, you can use an online form via the Office of the Privacy Commissioner of Canada website (https://www.priv.gc.ca/en/report-a-concern/).

GL-0026 Date of Production: October 2019 – Copyright © 2019 Cycle Pharmaceuticals Ltd. All rights reserved.

Privacy Statement – Intended for US Audiences Only

 Effective Date: June 1, 2020

Cycle Pharmaceuticals is committed to being transparent about the ways in which we collect and process your information. This privacy statement (“Privacy Statement”) describes our practices for handling the information we collect about you through our operations and services that include an authorized link to or reference to this Privacy Statement (“Services”). The Services include our websites and mobile apps that link to this Privacy Statement. This Privacy Statement applies to United States audiences only; if you are outside of the United States, please visit the applicable privacy statement here.

When this policy refers to us as “we,” “our”, or “Cycle,” it means Cycle Pharmaceuticals Limited and all of its affiliate companies located in the United States.

1.     Information We Collect

Depending on your relationship to Cycle, we may collect the following categories of information:

  • Identifiers, such as your name, contact information, and online identifiers.
  • Professional information and educational information, such as information about your medical specialty.
  • Demographic information, such as gender and marital status.
  • Medical, health, and biometric information, such as medical condition and biological characteristics.
  • Internet and electronic network activity information, such as your IP address and information about your interaction with our online Services.
  • Geolocation information.
  • Audio, electronic, and visual information, such as identifiable photographs and video.
  • Correspondence you send to us.

2.      How Do We Collect Information?

  • We collect information directly from you, such as when you provide information to our Services, whether electronically, by calling us, through other means, or when you authorize others to provide it to us.
  • We collect information about you through tracking tools and when we observe other information about you. See “Cookies and Similar Technologies” for more information.
  • Third parties may also share information about you with us. For example, our research partners and other partners may give us information. We may receive information from commercial sources such as companies that maintain information about health care providers and their specialties.
  • We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Statement.

3.     How We Use Information

We use and otherwise process each of the categories of information identified above for the following business purposes:

  • To provide you with the information, products and services that you request from us. This includes contacting you regarding such products and Services, such as to communicate information on the proper use of our products, and to provide, collect, review, and communicate information on the quality, safety, or effectiveness of our products.
  • To operate our business. We also may use your information to administer our services, including vendor management, troubleshooting, data analytics, testing, research, and statistical and survey activities.
  • For research and development of our products, including scientific, business, and market research.
  • To make suggestions and recommendations to you about products or Services that are similar to those you have enquired about or may otherwise be of interest to you, or to send you promotional materials from us or by our affiliates and trusted business partners.
  • To improve our Services, and to ensure that content is presented in the most relevant and effective matter for you and for your devices.
  • To keep our Services, business and users safe and secure, and to protect the rights and Services of others.
  • To comply with applicable legal and regulatory obligations, and to protect or exercise our legal rights or defend against legal claims. This includes using your information to comply with regulatory requirements relating to the safety and efficacy of our products.

4.     How We Share Your Personal Information

We may share the personal information we collect with certain third parties.

  • Regulatory requirements. We may use your information in submitting reports or other materials to the U.S. Food and Drug Administration. We may also use information you provide regarding your experience with any of our products to contact your healthcare professional regarding an unexpected event involving the use of any of our products.
  • Research purposes. We may share your information in connection with research and development, and in ensuring and promoting the safety and efficacy of our products.
  • Other third parties. We share your information with various service providers, contractors, agents, or partners in connection with business services they are providing with or on behalf of Cycle. Examples of such third parties include individuals and companies that develop, host or maintain our websites, or online resources, or those that provide customer service support activities. We also may share your information with third parties with whom Cycle is jointly marketing a product or service or jointly conducting a program or activity.
  • Corporate affiliates. We may share your information with our corporate affiliates.
  • Business transfers. We may share personal information in connection with a transaction involving all or part of our assets. For example, if all or part of Cycle is sold or merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. We may also share your information in the unlikely event of bankruptcy.
  • Legal purposes. We may disclose information to respond to legal process (such as a search warrant, subpoena, or court order), law enforcement requests, legal claims, or government inquiries. We may disclose information to protect and defend our rights or property, and to address security situations or emergencies when safety is at risk.
  • With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

5.     Cookies and Similar Technologies

When you use our Services, we and our third-party partners use cookies, pixel tags, local storage, local shared objects, and other similar technologies (collectively, “cookies”) to collect information about your browser or device. By using the Services, you consent to our use of cookies and similar technologies.

The following types of cookies are used on our Services:

  • Cookies. Cookies enable us to recognize when a computer being used to browse our website has previously visited a Cycle website. Cookies can also be used to enable a website to ‘remember’ the information a visitor has previously inputted, should that visitor so choose. Cookies may be placed on your computer both by us and by third parties with whom we have a relationship, such as web analytic services and advertising network services. For example, we use Google Analytics, and other analytical/performance cookies to help improve the way our website works.
  • Web beacons. On certain web pages or in e-mails we send to you, we may utilize a technology called a “web beacon” (also known as an “action tag” or “clear GIF technology”). We may use web beacons, for example, to help determine which email messages sent by us were opened and whether a message was acted upon. Web beacons also help analyze the effectiveness of websites by measuring, for example, the number of visitors to a website or how many visitors clicked on key elements of a website.
  • Social media plugins. The Services may use social plugins (e.g., the Facebook “Like” button) to enable you to post or easily share information with others. When you visit our website, the operator of the social plugin may be able to place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our website. If you are logged into the associated social media website (e.g., Facebook, Twitter, discussion boards, blogs, wikis,) while browsing on our website, the social plugin allows that social media website to receive information that you have visited our website. The social plugin may also allow the social media website to share information about your activities on our website with other users of their social media website. For more information about the information shared via a particular social media plugin, you should refer to that social media site’s privacy statement.
  • Other technologies. There are other local storage and Internet technologies, such as local shared objects (also referred to as “Flash cookies”) and HTML5 local storage, that operate similarly to the cookies discussed above. We also may collect mobile advertising IDs and similar device identifiers to collect your information.

You may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable certain types of tracking technologies, such as local shared objects. For example, local shared objects can be controlled through the instructions on Adobe’s Setting Manager page. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you and any differences in service are related to the data. Deleting cookies may in some cases cancel the opt out selection in your browser.

Some of our third-party partners are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. For additional information on how Google processes your information and what choices you may have, visit their site here. Due to differences between websites and mobile apps, you may need to take additional steps to opt out of interest-based advertising for mobile applications. Please check your device settings and mobile app permissions for additional information on how to opt out. You also may stop further data collection from a mobile application by removing it from your mobile device.

Do-Not-Track Signals and Similar Mechanisms. Certain web browsers and other programs may be used to signal your preferences to Cycle about how or whether Cycle or third parties may collect information about your online activities. Currently, Cycle does not respond to such signals.

6.     Your Rights and Choices

Depending on where you live, you may have certain rights under applicable laws, including

  • The right to access your personal information; and
  • The right request the deletion of certain personal information.

If you would like to access or delete your information, or otherwise exercise your rights, please contact us as set out in the Contact Us section below. We will respond in a manner that is appropriate in light of relevant laws. For example, we cannot provide you access to your personal information if we cannot verify your identity, and we may request further information from you to verify your request, such as, where necessary, copies of government-issued identification.

7.     Rights of California Residents

We will not discriminate against you for exercising your rights and choices, except where required or permitted by law. If you would like to use an authorized agent to exercise your rights, we may request evidence that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.

You also may have the right to be informed as to the categories of personal information that we have collected and shared or otherwise made accessible to third parties during the preceding 12 months. We provide that information through the other sections of this Privacy Statement. We share your information as described in this Privacy Statement, but we do not, and will not without consent, sell your information to third parties for money or other similar types of consideration.

In addition to other rights California residents may have under state law, California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as set out in the Contact Us section below. Be sure to include your name and address; you can include your email address if you want to receive a response by email. Otherwise, we will respond by postal mail within the time required by law.

8.     Transfer of Information Across International Boundaries

This Service is owned and operated by Cycle, but the information you provide may be accessible by, collected by or transferred to our affiliates and subsidiaries, vendors and suppliers in other countries. Furthermore, this Privacy Statement addresses only information that is or may be collected on our US Services, which are not intended to be used by non-US residents, or information otherwise collected in the United States. If you are using this Service from a country other than the United States, your communication with us will necessarily result in the transfer of information across international boundaries. By using this Service, you consent to the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.

9.     Job Applicants and Contractors

If you have applied for employment or a contract position with Cycle, the information submitted in your job application and that we otherwise collect in evaluating your application will be used for recruitment and other customary human resources purposes including any required government reporting and recordkeeping obligations. This information may include criminal record information and federal exclusion list status, as applicable.

10.  Children

We do not knowingly collect or sell any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law.

11.  Data Security

We take reasonable steps to protect your information from unauthorized access. You should keep in mind, however, that no internet transmission is ever 100% secure or error free. In particular, email sent to or from a website or online resource may not be secure, and you should therefore take special care in deciding what information you send to us via email. Moreover, where you use user IDs and passwords to access the Services, it is your responsibility to safeguard your access credentials. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

12.  Links to Other Websites

While our Services may provide links to other third-party websites as a service to our visitors, we do not endorse, nor are we responsible for the content of such third-party sites. Furthermore, this Privacy Statement does not apply to third-party websites, even if they are accessed through a link from a Cycle website or online resource or otherwise directed to by one of our Services. We encourage you to review the privacy policies of any third-party website before providing any personal information.

13.  Contact Information

Questions about this Privacy Statement may be directed to: steve.vincze@cyclepharma.com or you can write to us at:

Cycle Pharmaceuticals Limited
Attn: Privacy Officer
PO Box 130059
Boston, MA 02113, USA.
steve.vincze@cyclepharma.com
Telephone: +1-877-835-5784

California residents may also exercise their CCPA rights through a web form by clicking here: CCPA Privacy webform

14.  Changes

We reserve the right to amend this Privacy Statement at our discretion. When changes are made to this Privacy Statement, we will post the updated policy and the date the last revisions were made. We encourage you to periodically review this page for the most current Privacy Statement.

US-0271 Date of Preparation: June 2020 – Copyright © 2020 Cycle Pharmaceuticals Ltd. All rights reserved.

Introduction 

This Cookie Policy (“Cookie Policy”) explains how cookies are used on any web sites operated by, or on behalf, of Cycle (together “Cycle Website”). Cycle Pharmaceuticals Ltd, a company registered in England and Wales with company number 07933058 (“Cycle/We/Us”). Registered office address: Bailey Grundy Barrett Building, Little St. Mary’s Lane, Cambridge, Cambridgeshire, England, CB2 1RR. Cycle is a private limited company acting on behalf of itself and its subsidiaries.

Cycle Websites use cookies and similar technologies such as web beacons (sometimes called “tracking pixels” or “clear gifs”) and flash cookies (sometimes called local shared objects or “LSOs”). We refer to cookies and these similar technologies collectively as “cookies”, as such in this Policy, “cookie” means HTTP cookies which are small text files stored on your browser or computer hard drive when you access a Cycle Website. Cookies may be set by us or by third parties on behalf of Cycle.

Please visit www.allaboutcookies.org for more information about cookies.

Scope 

This Cookie Policy applies to any cookies (including third party cookies, web beacons and flash cookies) that are set by or on behalf of Cycle.

By using a Cycle Website, you understand that we may automatically collect and store information about your visit to a Cycle Website, through using browser cookies or similar devices. Through continuing to use a Cycle Website you consent to our use of cookies in the manner and for the purposes set out below.

How Cookies are Used Functionality

Some of the Cycle Websites use strictly necessary cookies to provide you a function of the Cycle Website. This may include:

  • Login settings to authenticate, maintain your login session and remember your preference in respect of storing your login credentials;
  • Tabbed content to record which tab is being viewed;
  • Regional content to provide region-based content and remember time zone settings;
  • Language settings to determine and remember which language to display content in;
  • Device functionality to provide different content depending on the browser device being used; and
  • Search settings to save all user-defined working sets that can restrict the scope of searches. If this data exceeds 4kb in size, further cookies are created as necessary.

Performance and Website improvement 

Some of the Cycle Websites use web analytics cookies and similar technologies to gain business insight, improve our understanding of how visitors use Cycle Websites (including developer activity) so we can review and update the content and functionality of Cycle Websites. We use the information (including your IP address) to identify webpages that are not being regularly visited and Cycle Website navigation issues.

The cookies collect information which includes the number of visitors to the site, where visitors have come to the site, and the pages they visited. These cookies may be set by us, or by third party companies such as:

  • Google Analytics

These are web analytics cookies, provided by Google Inc., that are used to collect information about how visitors use Cycle Websites. We use the information to compile reports and to help us improve Cycle Websites. The cookies collect information including the number of visitors to the site, where visitors have come to the site from, and the pages they visited.

The information generated by the cookie about your use of a Cycle Website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

Google will use this information for the purpose of evaluating your use of Cycle Website, compiling reports on Cycle Website activity for website operators and providing other services relating to Cycle Website activity and internet usage. Cycle does not attempt to reconcile information collected via Google Analytics to identify an individual user.

For more information about opting out of Google Analytics cookies please visit https://support.google.com/analytics/answer/181881?hl=en-GB.

By using a Cycle Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Personalisation 

Some Cycle Websites use cookies, web beacons or similar technologies to personalise the content that is displayed to you on a Cycle Website or to remember when you revisit our site. For example, we may use information about your visits to Cycle Websites in order to provide you with relevant content about Cycle products and services that may interest you. These cookies may be set by us, or by third party companies.

Cookie Retention 

We use a mixture of “session” cookies, (cookies stored in your web browser) and “persistent” cookies (which are stored for longer and which are activated each time you revisit a Cycle Website).

Your Choices Browser extensions

Some third parties such as Google Analytics have developed browser extensions to help you to manage their or other third party cookies.

Browser settings 

You can stop cookies being stored on your browser in future or delete any cookies that are already on your browser. To do so, refer to your browser manufacturer’s instructions by selecting “Help” in your browser menu.

Information on deleting or controlling browser cookies is available at http://www.AboutCookies.org/.

Third party cookies cannot be controlled by changing any Cycle Website settings, and if you have javascript disabled, you may not be able to change any Cycle Website settings. Please change cookie settings using your browser settings instead.

Local stored objects (“LSOs”) are used by the authors of files that are read by Adobe Flash Player and the websites hosting those files. To control or prevent LSOs being stored on your browser, refer to the Adobe website at http://www.adobe.com/privacy/flash-player.html.

Online Tools 

If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the Website Storage Settings Panel. You can also control Flash Cookies by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to “information” on the Macromedia website), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time).

Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

Please note that if you disable cookies entirely you may not be able to use certain areas or features of Cycle Websites.

Changes 

We reserve the right to change, modify, add or remove portions of this Cookie Policy at any time. If we make changes to this Cookie Policy then we will post an updated version of this Cookie Policy on the Cycle Websites.

Further Information 

If you have any questions or comments about this Cookie Policy then please contact us at marketing@cyclepharma.com or write to us at:

Barrett Grundy Bailey Building Little St. Mary’s Lane Cambridge, England CB2 1RR

GL-0026 Date of Production: October 2019 – Copyright © 2019 Cycle Pharmaceuticals Ltd. All rights reserved.

Comprehensive U.S. Compliance Program

(As required by the California Health & Safety Code section 119402)

Cycle Pharmaceuticals is leading-edge, rare disease pharmaceutical company committed to Innovation, Transformation and Treatment, reimagined.  We reimagine how drugs can benefit patients, to make their lives easier and improve their quality of life at every stage.

This commitment requires novel and transformative ways of thinking and working together. We encourage our colleagues to think differently, challenge conventional wisdom, and foster innovation, while always being guided by the best interest of patients.   In doing so, we are also committed to our Code of Business Conduct and Ethics (“the Code”) and the belief that the Code must be lived in a way that is respectful of each other, our stakeholders, and applicable laws, regulations, and industry standards. For this reason, we have developed a comprehensive  Compliance Program that includes the following elements.

Oversight & Governance
Our Board of Directors is committed to sound corporate governance principles. As part of this commitment, it has designated its Audit Committee to establish expectations for, oversee, and evaluate the effectiveness of our U.S. Compliance Program (“Compliance Program”). Cycle has designated a U.S. Chief Compliance Officer (“Compliance Officer”) to implement and oversee the Compliance Program that advances a culture of integrity and upholds our values. The Compliance Officer reports on a regular basis to the Audit Committee and to the General Counsel regarding the operations of all elements of the Compliance Program, including alleged violations and remedial or disciplinary measures.

Risk Assessment
Our Compliance Program is designed to address risks particular to our business activities. We assess various dynamics, including internal and external perspectives, as appropriate, to continually update our Compliance Program in light of the risks in a changing market.

Written Standards
Our Code of Business Conduct and Ethics (“the Code”) is designed to advance compliance with our guiding principles, applicable federal and state laws, and industry standards.  The commitments in the Code also include adherence to relevant industry codes, such as the PhRMA Code on Interactions with Healthcare Professionals. Our policies and procedures flow from the Code and must be consistent with it.

As required by California Health & Safety Code section 119402, Cycle has established an annual, aggregate dollar limit of $2,000.00 for certain spending on individual healthcare providers or other medical professionals licensed in the state of California. The value of meals provided in connection with business and educational discussions, and educational items, are included in this limit. This limit does not include the value of any grants for medical education or research, sponsorships, or fair market value payments for professional services. This limit may be revised from time to time by Cycle in its sole discretion. This limit represents an expenditure cap and not a goal or an average expenditure amount.

To the best of our knowledge, as of July 31, 2020, Cycle is in material compliance with its comprehensive Compliance Program and the requirements of the California Health & Safety Code section 119402.

Training & Communication
All Cycle employees and contractors who interact with Cycle U.S. business operations are trained on the Code and the policies and procedures that flow from it. Our approach to training is engaging, interactive, and inclusive of knowledge tests and certifications. Cycle also periodically reviews and updates its training programs to reflect developments in standards or understandings related to our comprehensive Compliance Program.

In addition to formal trainings, Cycle encourages ongoing communication across all levels of our Company. Our colleagues and contractors are encouraged to advance our culture of learning by proactively asking questions, seeking guidance, and making recommendations for improvements to business processes, training, and resources that support the Code and the work we do. Our colleagues and contractors have direct access to Human Resources, the Legal Department, and the U.S. Compliance Officer, and may communicate questions or concerns using our Compliance Hotline/Helpline +1-877-835-5784 resources, which include options for anonymity where permitted by law.

Monitoring & Auditing
Cycle’s U.S. Compliance Program regularly monitors and audits business activities to assess compliance with the Code and the policies and procedures that flow from it. Through these monitoring and auditing activities, the Compliance Program can identify potential or existing problems or areas of concern and take corrective action in an effort to prevent the recurrence of non-compliance as needed. The nature and extent of our monitoring and auditing varies due to a variety of factors, including the learnings from our Risk Assessment.

Reward & Remediation
Our Compliance Program is committed to a framework of personal, focused, and sustained recognition to encourage our colleagues and contractors who carry out their responsibilities as contemplated in our Code. This framework also includes features to remediate missteps and poor choices. All reports of alleged violations are investigated. We conduct fair and diligent investigation of matters that are brought to the company’s attention and seek to ensure consistent application of our standards.

In collaboration with our Leadership Team and under the supervision of the Board of Directors, our Compliance Program imposes remedial and disciplinary measures for violations.  Such measures are determined in Cycle’s sole discretion and may include counseling, re-training, oral or written reprimands, warnings, probation or suspension with or without pay, demotions, reductions in salary, termination of employment or service, and restitution, among other measures.

Annual Declaration: July 2020
To obtain a copy of this declaration and certification please email legal@cyclepharma.com

Last update: July 2020

US-0301 (Date of Preparation: July 2020)