Effective Date: September 1, 2019
We at Millendo have created this Privacy Notice to explain how we collect, use, disclose and otherwise process personal information in connection with operating our business.
Email us at firstname.lastname@example.org if you have questions about our Privacy Notice.
This Privacy Notice describes the privacy practices of Millendo Therapeutics Inc. and its subsidiaries and affiliates, including but not limited to Millendo Therapeutics SAS and Millendo Therapeutics Ltd (collectively, “Millendo”). This Privacy Notice describes how we collect, use, disclose and otherwise process personal information, and explains the rights and choices available to individuals with respect to their information.
Millendo may provide additional privacy notices to individuals at the time we collect their data. For example, we provide a specific privacy notice to clinical trial participants that describe our privacy practices in connection with conducting clinical trials. This type of an “in-time” notice will govern how we may process the information you provide at that time.
Please note, this Privacy Notice does not apply to Millendo’s processing of employee or contractor data.
Click on the links below to jump to sections of the Privacy Notice:
- Personal Information We Collect
- Our Use of Personal Information
- Personal Information We Share
- Cookies and Other Information Collected by Automated Means
- Online Choices
- Data Retention
- Information for Individuals in the European Economic Area and the United Kingdom
- How We Protect Personal Information
- Links To Websites And Third Party Content
- Updates To Our Privacy Notice
- How To Contact Us
Personal Information We Collect
Whose personal information we collect
We may collect personal information about individuals who interact with Millendo, including clinical trial participants, patients, patient family members, caregivers or advocates, physicians and other health care professionals, clinical trial investigators, researchers, pharmacists, contractors, consultants, job applicants, and volunteers.
How we collect personal information
We may collect personal information:
- Directly from individuals
- Through our websites and mobile applications
- From healthcare professionals
- From contract research organizations and clinical trial investigators
- From government agencies or public records
- From third party vendors, data brokers or business partners
- From industry and patient groups and associations
- From social media or other public forums (including adverse event information or product quality complaints)
- From recruiters
Types of personal information we collect
The types of personal information we collect include:
- Information we collect in connection with managing clinical trials, conducting research, and providing patient services (such as information about clinical trial participants, and medical or health information, including information about treatments for medical conditions and medications an individual may take, physical and mental health conditions and diagnoses, genetic information, and family medical history)
- Personal and business contact information (such as name, job title and employer name, email address, mailing address, and phone number)
- Biographical and demographic information (such as date of birth, age, gender, marital status, and information regarding any parents or legal guardians)
- Professional credentials, educational history, institutional affiliations, background checks, performance reviews, and information of the type included on a resume or curriculum vitae education and work history (such as work experience, education, salary, and languages spoken)
- Financial information we need to pay for services individuals may provide to us (such as tax identification number and financial account information)
- Publicly available information (such as comments describing support for and experience with Millendo products)
- Other information you provide to us (such as in emails, on phone calls, or in other correspondence with Millendo)
Our Use of Personal Information
We may use personal information for the following purposes:
- Communicate about the products and services we offer, and respond to requests, inquiries, comments, and suggestions
- Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read)
- Operate, evaluate and improve our business, our websites and mobile applications, and other products and services we offer (including to research and develop new products and services)
- Tailor the content we display in our communications and on our websites and in mobile applications
- Administer surveys and other market research
- Staff, facilitate, and manage clinical trials
- Track and respond to safety and product quality concerns (including product recalls)
- Comply with regulatory monitoring and reporting obligations (including those related to adverse events, product complaints, and patient safety)
- Analyze use of our products by clinical trial participants and patients
- Support public health initiatives and volunteer events
- Facilitate medication adherence programs
- Manage access to our products, including where access is limited by law to licensed physicians
- Facilitate academic and other research and studies
- Pay for services that physicians, researchers and other individuals may provide to us
- Manage patient advocacy, patient engagement, and product support programs (including to provide co-pay and other financial assistance where available)
- Identify and engage thought leaders and external experts
- Attribute authorship to academic and promotional materials
- Comply with legal or regulatory requirements, judicial process, and our company policies
- Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide
- Facilitate our recruitment activities (such as processing employment applications, evaluating a job candidate for an employment activity, and monitoring recruitment statistics)
We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.
Personal Information We Share
Millendo may share personal information for the purposes described in this Privacy Notice or a specific “in-time” privacy notice we may provide at the time we collect the information.
We may share personal information with:
- Millendo affiliates and subsidiaries
- Service providers that perform services on our behalf, including:
- Contract research organizations that conduct clinical trials on our behalf
- Clinical data storage and analytics providers
- Customer service and support providers (including for product quality and adverse event reporting, patient financial assistance, medicine intake adherence programs, etc.)
- Product recall vendors
- Technology providers (including technology support, email and web hosting providers, marketing and advertising technology providers, email and text communications providers, mobile application developers)
- Event planning and travel organizations that help facilitate Millendo programs
- Payment, shipping and fulfillment service providers
- Regulators worldwide, as required by law, including in connection with monitoring, review and approval of our studies, products and services, and adverse event reporting
- Partners with whom we jointly develop products or services
- Doctors, researchers, academics, and public health organizations
Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will – where required by applicable law – make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Notice. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.
In addition, we may share your information to comply with legal and regulatory requirements, and protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.
Cookies and Other Information Collected by Automated Means
We, our service providers, and our business partners, may also collect certain information about the use of our websites and mobile applications by automated means, such as cookies, web beacons and other technologies (“Automated Information”). Please see our Cookies Policy for more information on cookies. We and our service providers and business partners may collect Automated Information about your online activities over time and across our own and third-party websites when you use our websites and mobile applications. In jurisdictions where Automated Information is considered Personal Information, or if we associate Automated Information with personal information, we will treat Automated Information as personal information in accordance with this Privacy Notice.
The information that may be collected by automated means includes:
- Details about the devices that are used to access our websites or mobile applications (such as the IP address, and type of operating system and web browser)
- Dates and times of visits to, and use of, our websites and mobile applications
- Information about how our websites and mobile applications are used (such as the content that is viewed on our websites and how users navigate between our webpages, or the features of our mobile applications that are used and how users navigate between screens on our mobile applications)
- URLs that refer visitors to our websites
- Search terms used to reach our websites or locate our mobile applications
Web browsers may offer users of our websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. The “help” menu on most internet browsers contains information on how to disable cookies, or you can visit www.aboutcookies.org/how-to-control-cookies/.
We work with advertisers, advertising networks, advertising servers, and analytics companies (“Ad Partners”) that use different technologies to collect Automated Information in order to understand how our websites and mobile applications are being used and analyze where users go after they leave our websites and mobile applications in order to deliver relevant advertising. These advertisements may appear on other websites or services.
These Ad Partners may recognize a particular individual across third party websites over time and link various devices used by the same individual. For more information about how Ad Partners use the information collected by these technologies and about your options not to accept cookies placed by some of these companies on our websites and mobile applications, please visit WebChoices, the Digital Advertising Alliance’s consumer choice tool. If you are accessing the websites from the European Union, please visit the EDAA’s opt-out page, and if you are accessing the Sites from Canada, please visit the DAAC’s opt-out page. If you are using our mobile applications, please visit AppChoices to control interest-based advertising on apps on your mobile device via members participating in the Digital Advertising Alliance’s opt-out program.
The opt-outs described above are device- and browser-specific and may not work on all devices. If you choose to opt out through any of these opt-out tools, this does not mean you will cease to see advertising. Rather, the ads you see will be based on the website you are visiting and not your interests.
You may unsubscribe from receiving marketing or other commercial emails from Millendo by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as important product safety information, or changes in website on mobile application terms).
We will retain your information only for as long as necessary to fulfill the purpose(s) for which the information was collected, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may governs the retention of the data, and our legal or regulatory obligations. We will then destroy your information or anonymize the information, in accordance with applicable law.
Our websites and mobile applications are not intended for individuals under 18 years of age, and individuals must be at least 18 years of age to register with our websites and mobile applications. We do not knowingly collect personal information from children under age 13 through our websites or mobile applications. If we learn that we have collected personal information from a child under the age of 13 through our websites or mobile applications, we will delete that information.
Information for Individuals in the European Economic Area and the United Kingdom
Legal basis for processing data
In this section, we identify the legal grounds on which we rely to process personal information.
In some cases, Millendo has a legitimate interest to process the personal information that we collect, such as to develop, administer and support our products and services; to operate, evaluate and improve our business; to facilitate and manage clinical trials and other patient advocacy and engagement programs; to promote scholarly research; to support our recruitment activities; or to facilitate a sale of assets or merger or acquisition.
In other cases, Millendo processes personal information to fulfill our contracts with our business partners, such as healthcare providers, partners that maintain patient and investigator registries, and drug distributors.
It may be also necessary for Millendo to process personal information to comply with our legal obligations, and to protect against, identify, investigate, and respond to fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide. Millendo’s processing of certain health and other associated information may also be necessary for reasons of public interest in the area of health, such as with respect to adverse event and product safety reporting, or for scientific or historical research purposes.
Millendo may also process personal information as specifically permitted by applicable legal requirements, such as laws and regulations that authorize Millendo to process personal information for purposes of clinical trials.
If Millendo relies on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information. For more information on consent, please see the “Privacy Preferences, Rights and Choices” section of this Privacy Notice.
Privacy preferences, rights and choices
Individuals have certain rights and choices regarding Millendo’s processing of their personal information. We have appointed a Data Protection Officer (“DPO”) as a point of contact for exercising these rights. Please see the “How to Contact Us” section below for the DPO’s contact information.
Please note that if the exercise of these rights limits our ability to process personal information, we may be precluded from providing our products or services to individuals who exercise these rights, or from otherwise engaging with such individuals going forward.
We reserve the right to verify the identity of the individual in connection with any requests regarding personal information to help ensure that we provide the information to individuals to whom the information pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.
For information about the rights and choices users have with respect to cookies and online tracking, please see the “Cookies and Other Information Collected by Automated Means” section of this Privacy Notice.
General objections to the processing of personal information
To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. In some circumstances, withdrawing your consent to Millendo’s use or disclosure of your personal information will mean that Millendo will not be able to provide products or services to you or to otherwise engage with you.
Access to personal information
You may request access to the personal information that we maintain about you. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business, in a commonly used format. You may request to correct any errors in your personal information. We may reject your request to access or correct your information, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.
Portability of personal information
You may request that we transfer your personal information to another data controller. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.
Deletion of personal information
You may request that we delete your personal information. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.
International data transfers
We may transfer your personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. For example, if you are located outside of the United States, we typically transfer your personal information to the United States, where Millendo is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal information across borders, we consider a variety of requirements that may apply to such transfers.
Specifically, we may transfer personal information from the European Economic Area or the United Kingdom to:
- Countries that the European Commissions has deemed to adequately safeguard personal information,
- Pursuant to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield, or Binding Corporate Rules,
- Pursuant to the consent of the individual to whom the personal information pertains, or
- As otherwise permitted by applicable EEA requirements.
How we Protect Personal Information
Millendo maintains reasonable administrative, technical and physical safeguards designed to protect the personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot guarantee that the measures we maintain will ensure the security of the personal information.
Links to Websites and Third-Party Content
For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by Millendo. The websites and third-party content to which we link may have separate privacy notices or policies. Millendo is not responsible for the privacy practices of any entity that it does not own or control.
Updates to our Privacy Notice
Millendo reserves the right to change this Privacy Notice at any time. When we update this Privacy Notice, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Notice and providing other notification as required by applicable law. We may also notify you of changes to the Privacy Notice in other ways, such as via email or other contact information you have provided.
How to Contact Us
You may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices, or to request access to or correction of your information. Our contact information is as follows:
Millendo Therapeutics, Inc.
Attn: Legal Department – Privacy
110 Miller Avenue, Suite 100
Ann Arbor, MI 48104
If you are a resident within the European Economic Area, you also have the right to file a complaint with the supervisory authority of your member state.
Our data controllers located outside of the United States are:
Millendo Therapeutics SAS
15 Chemin du Saquin
Espace Européen, Building G
Effective Date: September 1, 2019.
What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating web domain on your subsequent visits to that domain. Most web pages contain elements from multiple web domains so when you visit the website, your browser may receive cookies from several sources.
Cookies are useful because they allow a website to recognize a user’s device. Cookies allow you to navigate between pages efficiently, remember preferences and generally improve the user experience. They can also be used to tailor advertising to your interests through tracking your browsing across websites.
Session cookies are deleted automatically when you close your browser and persistent cookies remain on your device after the browser is closed (for example to remember your user preferences when you return to the site).
What types of cookies does Millendo use?
We describe the categories of cookies Millendo and its contractors use below.
Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have asked for (such as navigating between pages) cannot be provided.
We make use of analytics cookies to analyze how our visitors use our Website and to monitor Website performance. This allows us to provide a high quality experience by customizing our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website. The information collected by these cookies is not associated with your personal information by us or by our contractors.
We permit Google Analytics to set performance cookies on the Website. You can opt out of Google Analytics here.
Website Functionality Cookies
If you do not agree to the use of these cookies, you may disable them by following the instructions for your browser as explained at http://www.allaboutcookies.org/manage-cookies/. Please note that some of our services may not function properly if cookies are disabled. You may also opt out of third-party cookies where available by using the links provided in this Cookies Policy.
Furthermore, some parties that set cookies via our site may offer the ability to opt-out of cookies via the Network Advertising Initiative’s consumer opt-out tool, the European Interactive Digital Advertising Alliance’s consumer opt-out tool, or the Digital Advertising Alliance’s Consumer Choice Page.
Cookies policy does not cover third party websites
Please note that this cookies policy does not apply to, and we are not responsible for, the cookie practices of third party websites which may be linked to this Website.
Changes to the Cookies Policy
We may update this cookies policy and we would encourage you to review the policy from time to time to stay informed of how we are using cookies.