Privacy Policy

Who we are?

Ribon Therapeutics is a clinical stage biopharmaceutical company operating from 35 Cambridgepark Drive, Cambridge, MA 02140.

Your Privacy

This policy provides information for individuals whose personal data has been collected by Ribon Therapeutics, whilst acting as the Sponsor of a clinical trial taking place in the UK or EEA. Under these circumstances we fall within scope of the General Data Protection Regulations (GDPR). As the sponsor of clinical trials in the UK or EEA, we will be obligated as the Data Controller for the study data generated.

Your privacy matters to us and we are committed to meeting regulatory data privacy standards and confidentiality.

Main Categories and Type of Personal Data Collected and processed in clinical trials

Below are details on the main categories and types of personal data collected and processed by Ribon Therapeutics.

As a clinical stage biopharmaceutical company, we collect various types of data from trial subjects. This data is pseudonymised and we are unable to identify subjects from this.  Access to identifiable personal data will only be by the site/hospital/clinic at which you as the trial subject attended. The types of data that we may collect from trial subjects includes but is not limited to:

• Subject Identifiers
• Age, Sex, and Ethnicity
• Health and Medical Information
• Blood Samples
• Urine Samples
• Tissue Biopsies

The study data will not be kept for longer than is necessary. To comply with the laws relating to clinical trials, this may be for up to 25 years. Details of how long study data is retained for is specific to a trial, this can be found in the Patient Information Sheet provided to trial subjects.

We collect and process study data on the basis of legal requirements and in the interest of public health. All study subjects will have been provided information on the processing of their personal data when consenting to take part in the trial.

During clinical trials we will also collect the personal data of staff conducting the study on our behalf.

The types of data that we may collect from trial staff includes but is not limited to:

• Names, contact details, and work address
• Qualifications, experience, and training
• Financial declarations and details

We collect and process this personal data on the basis of a contractual relationship and will only retain this data outside of the study data for future use with consent. All data related to the trial is retained in accordance with clinical regulations and could be up to 25 years.

Collection of online identifiers for analytical purposes (Cookies)

When you use our website, we may also collect certain information by automated means, such as cookies and web beacons. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We may also use third-party analytics tools (such as Google Analytics) that collect information about use of the website and user traffic. The information we may collect by automated means may include, without limitation:

• Cookie information
• IP address
• Device ID
• Session ID
• Interaction history

We only collect this information with your consent, to ensure visitors get the best experience to the website.

For information on how long this data is stored, please see our cookie policy.

Sharing of Personal Data

Ribon Therapeutics may pass the clinical trial study data on to service providers contracted to provide specialist functions, such as, safety monitoring, statistical analysis, report writing etc. Our service providers are under contract with us and have provided sufficient guarantees that they will process your data only as per the terms of that contract and throughout processing activities will ensure your data is protected using appropriate technical and organisation measures. Once your data is no longer needed to fulfil the service, they will dispose of the details in line with Ribon Therapeutics procedures.

A full list of processors is available upon request.

Where necessary or requested, we may disclose your information to relevant regulatory bodies or agencies responsible for the regulation of clinical trials.

UK and EU Data Subjects- International Data Transfers

In some instances, we may transfer your personal information to third countries, for example, where our service providers or suppliers are situated outside the UK and EEA.

If the recipient is situated in a third country that has not received an adequacy decision from the relevant UK or EU regulator, we will ensure additional safeguards are in place including the use of applicable standard contractual clauses.

Securing and Processing of your Personal Data

To provide and manage our services your electronic data is stored and processed by internal and external systems. All our systems have appropriate security processes in place. These systems can differ with each trial. If you would like more information on the security measures in place for the system that your data is stored on, please contact us with details of the trial.

Your rights in relation to personal data

Ribon Therapeutics conducts trials across the world and abides with each countries Data Protection law. Each countries law provides its residents with rights to their data these can include:

Right to be Informed:
This means that we have to be transparent in how we collect and use your personal data

Right of Access:
You have the right to access your personal data

Right to Rectification:
If the information we hold about you is inaccurate or incomplete you can request that we correct this

Right to Erasure:
You can request that we delete or remove personal data in certain circumstances (Not applicable to clinical trial study data)

Right to Restrict Processing:
You have the right to request that we cease processing your data if

• you consider it inaccurate or incomplete and/or
• you object to the reason we’re processing your data

We will review the validity of your request and respond to you with our decision

Right to Data Portability:
Where you have consented to our processing your data or where the processing is necessary for us to deliver a contract you can request a copy of that data be provided to a third party

Right to Object:
You have the right to object to our processing in certain circumstances.

Rights relating to Automated Decision-Making including Profiling:
We do not use automated decision-making or profiling

Where automated decision-making is applied, organizations must

• give you information about the processing
• introduce simple ways for you to request human intervention or challenge a decision
• carry out regular checks to make sure that our systems are working as intended

How to exercise these rights?

If you took part in a clinical trial as a study subject, you should ideally contact the institute where your trial took place (as we will not be able to identify you from the study data). Contact details will have been given on your Informed Consent Form or Patient Information Sheet. Failing this you can contact us directly using the details below.

If you took part in a clinical trial as part of the study team, please contact us using the details below to exercise your rights.

Gary Sutton
Chief Business Officer
[email protected]

If you are unhappy with anything we have done with your data, you have the right to complain to the relevant supervisory authority in your country.