Privacy Notice

Last Updated: August 2023 

1. Introduction and Scope of Privacy Notice

Aktiv Pharma Group (“Aktiv”, “us”, “we”, “our”) knows that you care how information about you is used and shared, and we appreciate your trust that we will respect your privacy, and do so carefully and sensibly. 

This Privacy Notice informs you how and why we use your “Personal Data” (i.e., information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household) when you visit the “aktivpharmagroup.com” website (”Website”) and informs you of your privacy rights in relation to your Personal Data.  

In particular, this Privacy Notice applies to Personal Data collected about you by Aktiv via the Website including, through forms on the Website and electronic correspondence between you and the Website. This Privacy Notice does not apply to Personal Data collected: 

  • By us (or our vendors), offline or through any other means including, should you enroll in a clinical study. In such cases, we will provide you with a further privacy notice addressing the processing of your Personal Data in this context;

  • Through any of our other websites (including those specific to our clinical studies); or

  • By any third party, including through any application or content (including advertising) that may link to or be available from the Website.

By accessing the Website, you agree to our collection and use of Personal Data as described in this Privacy Notice and our Terms of Use.

If you have any questions about this Privacy Notice, including any requests to exercise your privacy rights please contact us via the Contact Form.

2. Changes to the Privacy Notice and your duty to inform us of changes 

We reserve the right to modify this Privacy Notice at any time, so please review it frequently. If we make changes that materially affect our use of Personal Data or your privacy rights, we will announce the changes on our Website or, if appropriate, by email. 

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us. 

3. The Personal Data we collect about you 

We may collect, use, store, transfer and otherwise process different categories of Personal Data about you as set out below. 

  • Contact Data includes email address and telephone numbers. 

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website. 

  • Usage Data includes information about how you use our Website.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

4. If you fail to provide Personal Data 

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that Personal Data when requested, we may not be able to comply with our legal obligations, provide you with a service or perform the contract we have or are trying to enter into with you. In such case, we may have to terminate our relationship with you. 

5. We use different methods to collect Personal Data from and about you including through: 

5.1 Direct interactions. You may give us your Personal Identifier Data, Contact Data and Financial Data by filling in forms or by corresponding with us through the Website. This includes Personal Data you provide when you: 

  • Inquire about our business; 

  • Submit an inquiry via the Inquiry Form;  

  • Sign up for email alerts; 

  • Give us some feedback; or 

  • Otherwise contact or interact with us. 

5.2 Automated interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies. For information about our use of cookies, please see our Cookies Policy. 

5.3 Third parties (or publicly available sources). We may receive categories of Personal Data about you from various third parties and public sources as set out below: 

  • Technical Data from analytics providers such as Google; advertising networks and search information providers. 

  • Personal Identifier Data and Contact Data from publicly available sources such as voter registration lists. 

6. Purposes for which we will use your Personal Data 

We may use your Personal Data to:

  • Manage our relationship with you which will include: 

(a) Notifying you about changes to our terms or privacy policy 

(b) Responding to your inquiry 

  • Administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

  • Deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you 

  • Use data analytics to improve our Website, marketing, customer relationships and experiences 

  • Make suggestions and recommendations to you about goods or services that may be of interest to you  

7. Disclosures of your Personal Data 

We may have to share your Personal Data with the parties set out below for the purposes set out in the table above. 

  • Internal Third Parties: other companies or departments in Aktiv where they e.g., provide IT and system administration services and undertake leadership reporting 

  • External Third Parties: service providers acting as processors e.g., who provide IT and system administration services 

  • Other Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Notice. 

  • Professional advisers: including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting and payroll services. 

  • HM Revenue & Customs, Regulators and other authorities who require reporting of processing activities in certain circumstances. 

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.  

We do not sell Personal Data collected through the Website. 

8. International transfers 

We are located in the US and Personal Data collected via the Website is hosted in the US. As such, if you are located outside of the US, your Personal Data collected via the Website will be transferred to the US at all times in accordance with data protection laws. 

Where we transfer your Personal Data to other recipients, we will only do so where such transfer is in compliance with applicable data protection laws, including, where required, implementing standard contractual clauses with the recipient, relying on the recipient’s Binding Corporate Rules, or by relying on a derogation such as, where the transfer is necessary for performance or a contract or the establishment or defense of legal claims. You can request further information in relation to international transfers (including a copy of any standard contractual clauses) by using the contact details set out above.  

9. Data security 

We are committed to protecting the security and privacy of your Personal Data. We maintain reasonable and appropriate technical, organizational, administrative and physical security procedures and practices designed to protect the security, confidentiality, and integrity of Personal Data.  While we are committed to safeguarding your Personal Data through our information security program, even the most stringent security program may not always be able to prevent all security breaches. 

10. Data retention 

We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

11. Third party websites 

The Website displays social media buttons.  When you click on any of those buttons, your Personal Data may be transferred to these companies and they may also set cookies or other tracking technologies on your browser.  The privacy policies and terms of use of each of those companies govern the collection and use of your Personal Data when you click on their buttons on our Website. 

Our Website may also contain links to other websites that we do not operate and for which this Privacy Notice does not apply.  We encourage you to read the privacy policies of all of the destination websites you visit. 

12. Contact Information 

If you have any questions about this Privacy Notice or our data protection policies, please contact us via the Contact Form.