Privacy Policy

Effective Date: March 1, 2023

This Privacy Policy describes how Auregen BioTherapeutics and its affiliates (“Auregen,” “we,” “us” and “our”) handles personal information that we collect through our websites and any other sites or services that link to this Privacy Policy (collectively, the “Services”).

Personal Information We Collect

Information provided by you:

Contact details, such as your first and last name, address, email and phone number.
Communications that we exchange with you, including when you contact us with questions, feedback or otherwise.
Usage information, such as information about how you use the Services and interact with us, including information you provide when you use any interactive features of the Services.
Marketing information, such as your preferences for receiving communications about our Services, and details about how you engage with our communications.
Other information that we may collect, which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We and our service providers may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the Services, online resources and our communications, such as:

Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers, language settings and general location information such as city, state or geographic area.
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, duration of access and whether you have opened or otherwise engage with our communications, such as our marketing emails or clicked links or files within them.

We collect this information using cookies and other similar technologies. For more information, please visit our Cookie Policy.

Information we obtain from other sources:

Social media information. We may maintain pages on social media platforms, such as Facebook, Twitter, and LinkedIn. When you visit or interact with our pages on those platforms, you or the platforms may provide us with information through the platform.
Other sources. We may obtain personal information from other third parties, such as publicly-available sources and data providers.

How We Use Personal Information

We use personal information for the following purposes or as otherwise described at the time of collection:

Provide our Services. We use personal information to operate, maintain, and provide you with our Services. In particular, we use personal information to perform our contractual obligations under our terms of use.

Communicate with you about our Services. It is in our legitimate business interests to use personal information to respond to your requests, provide customer support, and communicate with you about our services, including by sending announcements, updates, security alerts and support and administrative messages.

Improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our services safe for our users, which includes:

understanding your needs and interests, and personalize your experience with the Services and our communications;
troubleshooting, testing and research and to keep the Services secure; and
investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.

Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

Direct marketing. We may send you direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the “Opt-out of marketing communications” section below. Except where consent is required, we undertake such marketing on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to:

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 and internal policies;
enforce the terms and conditions that govern the Services;
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

How We Share Personal Information

We may share personal information with the following entities:

Service providers. Companies and individuals that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, customer support, email delivery and website analytics services).

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. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Auregen (including, in connection with a bankruptcy or similar proceedings).

Affiliates. Our corporate affiliates for purposes consistent with this Privacy Policy.

Privacy Rights and Choices

Opt-out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the “How to Contact Us” section below. You may continue to receive Services-related and other non-marketing emails.

Online tracking opt-out. You limit the use of cookies as described in our Cookie Policy.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information:

Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
Correction of personal information that is inaccurate or out of date.
Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
Additional rights, such as to object to and request that we restrict our use of personal information.

To make a request, please email us or write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below. Depending on where you reside, such as if you reside in the European Economic Area or United Kingdom, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.

Do Not Track. Some Internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other Sites and Services

Our Services may contain links to websites 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 or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.

Security

We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

International Data Transfers

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the “How to Contact Us” section below.

Retention

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

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 personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Job Applicants

When you visit the “Careers” portion of the website, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information on the basis of our legitimate business interests to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics and to respond to surveys. We may also use this information to provide improved administration of the services and as otherwise necessary (i) to comply with relevant laws or to respond to subpoenas or warrants served on us, (ii) to protect and defend our or others’ rights or property, (iii) in connection with a legal investigation and (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy or our terms of use.

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 the website.

How to Contact Us

Responsible entity. Auregen is the entity responsible for the processing of personal information under this Privacy Policy (as a controller, where provided under applicable law).

Contact us. If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at info@auregen.bio or write to us at:

Auregen BioTherapeutics, Inc.
55 Cambridge Parkway
Cambridge, MA 02142, USA

Auregen BioTherapeutics SA
Dreikönigstrasse 31A
8002 Zürich, Switzerland

Auregen BioTherapeutics GmbH
Aspenhaustraße 25
72770 Reutlingen, Germany