Privacy Policy
Effective as of October 18, 2025.
Last updated October 18, 2025.
California Notice at Collection: See the California Privacy Rights Notice below for important information about your rights under applicable California law.
This Privacy Policy describes how Kura Oncology, Inc. (“Kura,” “we“, “us” or “our“) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our websites, and social media pages) as well as our marketing activities, patient assistance programs, live events and other activities described in this Privacy Policy (collectively, the “Services”). Kura may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information; for example, in the context of conducting clinical trials, we provide disclosures related to our personal information practices in conducting such trials.
Kura may process personal information that identifies your past, present, or future health status, or that otherwise constitutes “consumer health data” or equivalent terms as defined by applicable US state laws (“Consumer Health Data”). To the extent such laws apply to your Consumer Health Data, please see our Consumer Health Data Privacy Policy, which supplements this Privacy Policy.
Our personal information practices may vary depending on the nature of the Services you use and our relationship to you. For example, we may collect health-related data about individuals participating in patient assistance programs, while we generally do not collect such data from for general website visitors. Please consider the context in which we interact with you when reading this Privacy Policy.
NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe;” “European” should be understood accordingly) below.
Index
- Personal Information We Collect
- Tracking and Other Technologies
- How We Use Your Personal Information
- Retention
- How We Share Your Personal Iinformation
- Your Choices
- Other Sites and Services
- Security
- International Data Transfer
- Children
- Changes to this Privacy Policy
- How to Contact Us
- California Privacy Rights Notice
- Notice to European Users
Personal Information We Collect
Information you provide to us or that we generate about you. Personal information you may provide to us or our service providers through the Services or otherwise or that we may generate about you includes:
- Contact information, such as your first and last name, salutation (e.g., Mr., Mrs., Ms.), email address, mailing addresses, and phone number.
- Demographic data, such as your city, state, country of residence, postal code, gender, ethnic origin/race and date of birth.
- Health-related data, such physical health history, conditions and diagnoses, treatments, medications, and other physical health information.
- Communications data based on our exchanges with you, including when you contact us through the Services, social media, or otherwise.
- Transactional data, such as tax identification number, bank account information and other financial information, and information relating to your prescription orders for approved products.
- Payment data, such as unique IDs to facilitate your use of our co-pay cards.
- Insurance and benefits-related data, such as your insurance policy number or information about your insurance and benefits history.
- Professional data, such as name, professional title and employer name, national provider identification number (NPI) or similar, work contact information, signature, CV information, professional licensure information, travel information, picture/video/audio material, and education and professional experience.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Through our digital or online properties, unless we specifically direct you otherwise, we ask that you not provide us with any health-related information (including any information regarding your past, present or future physical or mental health status).
Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:
- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Data providers, such as information services and data licensors.
- Partners, such as commercialization partners and medical institutions.
- Caregivers, such as family members, health care professionals and medical institutions.
- Service providers that provide services on our behalf or help us operate the Services or our business.
- Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Services, our communications and other online services, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
- Precise geolocation data, which are collected from some Services for analytics purposes.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
- Communication interaction data, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
For more information concerning our automatic collection of data, please see the Tracking and Other Technologies section below.
Tracking and Other Technologies
Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Services.
For information concerning your choices with respect to the use of tracking technologies, see the How can you manage your consent section of our Cookie Policy.
How We Use Your Personal Information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
- provide the Services and operate our business;
- enable security features of the Services;
- communicate with you about the Services, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and
- provide support for the Services, and respond to your requests, questions and feedback.
Service personalization, which may include using your personal information to:
- understand your needs and interests;
- personalize your experience with the Services and our Service-related communications; and
- remember your selections and preferences as you navigate webpages.
Service improvement and analytics. We may use your personal information to analyze your usage of the Services, improve the Services, improve other aspects of our business, help us understand user activity on the Services, including which pages are most and least visited and how visitors move around the Services, as well as user interactions with our emails, and to develop new products and services. For more information on analytics, see our Cookie Policy. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes, as follows:
- Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt out of our marketing communications as described in the Opt out of E-mail Marketing Communications section below.
- Interest-based advertising. We and our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the Tracking technologies section above) with the Services, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in our Cookie Policy.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Services; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Data sharing in the context of corporate transactions. We may share certain personal information in the context of actual or prospective corporate transactions with business transferees – for more information, see How we share your personal information below.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We convert personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data except as otherwise permitted by applicable law. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which the information was collected.
Retention
We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, and for fraud prevention purposes. To determine the appropriate retention period for your personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
How We Share Your Personal Information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Service providers. Third parties that provide services on our behalf or help us operate the Services or our business, such as those involved in data hosting, information technology, customer support, pharmacy services, patient support services, payment card services, customer service-related services, order fulfillment, email delivery, marketing, consumer research and/or website analytics.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so such as with caregivers and healthcare professionals.
Partners. Third parties with whom we partner, such as our commercialization partners, collaboration partners and research institutions.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of Kura, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisors. We may also disclose your personal information to an acquirer, successor, or assignee of Kura as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Your Choices
In this section, we describe the rights and choices available to all users. Users who are located in California and Europe can find additional information about their rights below.
Opt out of email marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies and other tracking technologies. For information about cookies employed by the Services and how to control them, see our Cookie Policy.
Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. Some, but not all, of our websites respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Other Sites and Services
The Services may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International Data Transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Users in Europe should read the important information provided below about transfer of personal information outside of Europe.
Children
The Services are not intended for use by anyone under 16 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Services from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on www.kuraoncology.com or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Services after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Services and our business.
How to Contact Us
If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you, please contact us at privacy@kuraoncology.com.
California Privacy Rights Notice
Except as otherwise provided, this notice applies to residents of California, pursuant to the California Consumer Privacy Act (“CCPA”).
This notice describes how we collect, use, and share Personal Information (as defined below) of residents of California and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of California, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.
For purposes of this notice, the term “Personal Information” has the meaning given to “personal information” or other similar terms in the CCPA and “Sensitive Personal Information” has the meaning given to “sensitive personal information” or other similar terms in the CCPA, except that in neither case does such term include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of residents of California, such as job applicants, in which case that notice will apply instead of this notice.
Your privacy rights. The CCPA may provide residents with some or all of the rights listed below. However, these rights are not absolute. Therefore, we may decline your request in certain cases as permitted by law.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with which we share Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
- Access. You can request a copy of the Personal Information that we have collected about you.
- Appeal. You can appeal our denial of any request validly submitted.
- Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Opt out of Selling or Sharing. You can opt out of certain processing or “sharing” of Personal Information; for example, for targeted advertising purposes. You may also have the right to opt out of other sales of your Personal Information; however, we do not sell your Personal Information for monetary consideration.
- Consumers under 16. We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.
- Limit processing of Sensitive Personal Information. You have the right under the CCPA to limit the processing of certain uses of Sensitive Personal Information. However, we do not use Sensitive Personal Information in a way that requires us to provide you with a right to limit.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
Right to information, access, correct and deletion. You can request to exercise your information, access, correct and deletion rights by:
- Email: privacy@kuraoncology.com
- Phone: 877-827-0485
Right to opt out of the “sharing” of your Personal Information. While we do not sell Personal Information for money, like many companies, we use services that help deliver interest-based ads to you as described above. The CCPA may classify our use of some of these services as the “sharing” of your Personal Information with the advertising partners that provide the services. You can submit requests to opt out of tracking for targeted advertising purposes or other similar sharing of Personal Information by selecting the Do Not Sell or Share My Personal Information option and disabling marketing cookies.
You can also broadcast the Global Privacy Control (GPC) to opt out for each participating browser system that you use. Learn more at the Global Privacy Control website.
Verification of Identity; Authorized agents. We may need to verify your identity in order to process your information, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.
Under the CCPA, you may enable an authorized agent to make a request on your behalf upon. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your California privacy rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.
Personal information that we collect, use and disclose. We have summarized the Personal Information we collect and may disclose to third parties by reference below to both the categories defined in the “Personal information we collect” section of this Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140). The information below describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.
| Personal Information (“PI”) we collect | CCPA statutory category | Categories of third parties to whom we “disclose” PI for a business purpose | Categories of third parties to whom we “sell” or “share” PI |
| · Contact information | · Identifiers (online)
· Identifiers (other) · Commercial information · California customer records |
· Service providers
· Payment processors · Advertising partners · Third parties designated by you · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Demographic data | · Identifiers (online)
· Identifiers (other) · California customer records |
· Service providers
· Payment processors · Advertising partners · Third parties designated by you · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Health-related data | · Identifiers (online)
· Identifiers (other) · Commercial information · California consumer records · Internet or Network Information |
· Service providers
· Payment processors · Third parties designated by you · Health insurance and benefits partners · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Communications data | · Identifiers (online)
· Identifiers (other) · Commercial information · California consumer records · Internet or Network Information |
· Service providers
· Payment processors · Third parties designated by you · Health insurance and benefits partners · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Transactional data | · Commercial information
· California consumer records · Financial information |
· Service providers
· Payment processors · Third parties designated by you · Health insurance and benefits partners · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Payment data | · Commercial information
· California consumer records · Financial information |
· Service providers
· Third parties designated by you · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Insurance and benefits-related data | · Commercial information
· California consumer records
|
· Service providers
· Health insurance and benefits partners · Third parties designated by you · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Professional data | · Identifiers (online)
· Identifiers (other) · Commercial information · California customer records |
· Service providers
· Payment processors · Advertising partners · Third parties designated by you · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Marketing data | · Identifiers (online)
· Identifiers (other) · Commercial information · California customer records · Internet or Network Information |
· Advertising partners
· Payment processors · Professional advisors · Authorities and others · Business transferees |
· None |
| · Precise geolocation data | · Identifiers (other)
· Internet or Network Information |
· Service providers
· Payment processors · Advertising partners · Third parties designated by you · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Device data | · Identifiers (other)
· Internet or Network Information |
· Service providers
· Advertising partners · Third parties designated by you · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Online activity data | · Identifiers (other)
· Commercial information · Internet or Network Information |
· Service providers
· Advertising partners · Third parties designated by you · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Communication interaction data | · Identifiers (online)
· Identifiers (other) · Commercial information · California consumer records · Internet or Network Information |
· Service providers
· Third parties designated by you · Professional advisors · Authorities and others · Business transferees · Business and marketing partners |
· None |
| · Data derived from the above | · Inferences | · Service providers
· Advertising partners · Authorities and others · Business transferees · Business and marketing partners |
· None |
Additional information for Nevada residents. Nevada residents have the right to opt out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email privacy@kuraoncology.com.
Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section above.
Notice to European Users
General
Where this Notice to European users applies. The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “Europe”).
Personal information. References to “personal information” in this Privacy Policy include “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”). Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect”.
Controller. Kura is the “controller” in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details. Our data protection officer can be reached at 4930 Directors Place, Suite 500, San Diego, CA 92121 or privacy@kuraoncology.com.
Our GDPR Representatives. We have appointed DataRep as our data protection representative in Europe as required by the GDPR – you can contact them directly should you wish, as follows:
By email: datarequest@datarep.com, identifying Kura Oncology in the subject line
Online: https://www.datarep.com/data-request/
By mail: mailing an inquiry to DataRep at the most convenient of the addresses set forth below.
Please ensure post is addressed to “DataRep” and not Kura Oncology, Inc.
| COUNTRY | ADDRESS |
| Austria | DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria |
| Belgium | DataRep, Rue des Colonies 11, Brussels, 1000 |
| Bulgaria | DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria |
| Croatia | DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia |
| Cyprus | DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus |
| Czech Republic | DataRep, Platan Office, 28. Října 205/45, Floor 3&4, Ostrava, 70200, Czech Republic |
| Denmark | DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark |
| Estonia | DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia |
| Finland | DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland |
| France | DataRep, 72 rue de Lessard, Rouen, 76100, France |
| Germany | DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany |
| Greece | DataRep, Ippodamias Sq. 8, 4th floor, Piraeus, Attica, Greece |
| Hungary | DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary |
| Iceland | DataRep, Kalkofnsvegur 2, 3rd Floor, 101 Reykjavík, Iceland |
| Ireland | DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland |
| Italy | DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy |
| Latvia | DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia |
| Liechtenstein | DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria |
| Lithuania | DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania |
| Luxembourg | DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg |
| Malta | DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta |
| Netherlands | DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands |
| Norway | DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway |
| Poland | DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland |
| Portugal | DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal |
| Romania | DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, Romania |
| Slovakia | DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia |
| Slovenia | DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia |
| Spain | DataRep, Calle de Manzanares 4, Madrid, 28005, Spain |
| Sweden | DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE – 211 46, Sweden |
| United Kingdom | DataRep, DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom |
Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.
Our legal bases for processing your personal information described in this Privacy Policy are listed below.
- Where we need to process your personal information in order to deliver the Services to you, or where you have asked us to take specific action which requires us to process your personal information (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see the ‘How we use your personal information’ section above and the description of associated data sharing relevant to such purposes set out in the ‘How we share your personal information’ section also above.
| Purpose | Categories of personal information involved
|
Legal basis |
| Service delivery and operations | Contact information
Demographic data Communications data Transactional data Professional data Precise geolocation data Device Data |
Contractual Necessity.
Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Services, our business and associated IT services, systems and networks. |
| Service personalization | Demographic data
Device data Online activity data |
Legitimate Interests. We have a legitimate interest in providing you with a good service and personalizing it to further this purpose.
Consent, in respect of any optional cookies used for this purpose. |
| Service improvement and analytics | Demographic data
Device data Online activity data |
Legitimate Interests. We have a legitimate interest in providing you with a good service and analysing how you use it so that we can improve it over time, as well as developing and growing our business.
Consent, in respect of any optional cookies used for this purpose. |
| Direct marketing | Contact information
Communication Interaction data Marketing data |
Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose.
Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications. |
| Interest-based advertising | Device data
Online activity data |
Consent, in respect of any optional cookies used for this purpose. |
| Compliance and protection | Any and all data types relevant in the circumstances | Compliance with Law.
Legitimate Interests. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety. |
| Data sharing in the context of corporate events | Any and all data types relevant in the circumstances | Legitimate Interests. We have a legitimate interest in pursuing and consummating actual or prospective corporate events and providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations). |
| To create aggregated, de-identified and/or anonymized data | Any and all data types relevant in the circumstances | Legitimate Interests. We have legitimate interest in taking steps to preserve our users’ privacy as we research how they use our Services. |
| Further uses | Any and all data types relevant in the circumstances | The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected.
Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected. |
Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for the ‘Compliance and protection’ purposes outlined above.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information that we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Other information
No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Services to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Services to you. We will notify you if this is the case at the time.
No sensitive information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetics characteristic) on or through the Services, or otherwise to us or your healthcare professional, unless we specifically request it. If you provide us with any such sensitive personal information to us when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Services. As a reminder, Kura may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information; for example, in the context of conducting clinical trials, we provide disclosures related to our personal information practices in conducting such trials.
Your additional rights
General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
- Restrict. Restrict the processing of your personal information, for example if you would like us to establish its accuracy or the reason for processing it.
- Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
- Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.
Exercising These Rights. You may submit these requests by contacting us (see ‘How to contact us’). We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
- For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
- For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/
Data Processing outside Europe
We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Services, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:
- Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
- Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S.).
- However, in these cases:
- we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
- in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
You may contact us if you would like further information on the specific mechanism used by us when transferring your personal information out of Europe.