Privacy

Effective Date: 09-12-2022

Invaio Sciences, Inc. and its subsidiaries and affiliates, including, without limitation, Invaio Sciences International GmbH, Invaio Sciences (Italy) S.R.L., Invaio Sciences, Ltda and Invaio Sciences (Spain), S.L. (together, "Invaio," "we," "us" or "our") is committed to respecting your privacy. Invaio is a data controller for the purposes of European data protection laws. Invaio’s contact details can be found below. Invaio’s Data Protection Officer can be reached at [email protected].This Privacy Notice ("Notice") will tell you how Invaio collects, stores, uses and processes the personal data and information we collect about you through this website.

 

Privacy Policy Highlights

What Information Do We Collect?

You may choose to provide us the following information:

• Contact Information – we collect your name, email and postal address, and telephone number when you provide it to us to contact you.
• Career Submissions – we collect your resume/CV and contact details.
• Investor, Media, Update Subscription or General Inquiries – we collect your name, email address, mailing address, telephone number and other contact details.

We may also collect your IP address, pages visited, time spent on the site, browser and device type, language and date of your visit.

 

How Do We Use Your Information?

We use your personal data to contact you when you give us your consent to do so.

We use your personal data for the following legitimate business purposes:

• To submit investigational and marketed product reports as required by law
• To process your application for employment
• To monitor, improve and administer the Invaio Sites and the services provided on the Invaio Sites
• To provide you updated information regarding our products, programs and services
• To inform you of significant changes to this Notice
• To detect and prevent fraud and to comply with and enforce our legal requirements
• To provide Invaio.com, our branded websites and mobile apps, and any other websites that link to this Notice to you (together, the "Invaio Sites")

 

Who Do We Share Your Information With?

• Our service providers, which are contractually obligated to provide services to us in a manner consistent with this Notice
• As part of a merger, acquisition or other sale or transfer of Invaio and/or any of its affiliates to another party

 

How Long Do We Retain Your Information?

• We retain the information we collect to test, develop and market our products as long as required by law. We may retain your information for archival and research purposes.
• If you submit information through our Invaio Sites, we will retain it for as long as required to process your requests.

 

Our Cookie Policy

Invaio.com uses Google Analytics. You can opt-out of Google Analytics here.

 

What Are Your Rights and Choices?

You always have the right to:

• Obtain confirmation that Invaio has collected your personal data and details on how we use your personal data and/or obtain a copy of your personal data
• Verify the accuracy of your personal data
• Request that we correct, update, amend, delete, or transform your personal data into an anonymous form
• Request that we restrict our use of your personal data
• Request the portability of your personal data
• Withdraw you consent at any time
• Object to the processing of your personal data on legitimate grounds

 

International Transfer of Information

• We collect and receive data from inside and outside of the United States.
• We will use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the EU and where required implement additional safeguards.

 

How Do We Protect Your Personal Data?

Invaio uses technical and organizational security measures to guard against unauthorized access to your personal data or against the unauthorized alteration, disclosure, destruction and/or loss of such data.

 

Full Privacy Policy

I. What Information Do We Collect?

We collect personal data from you when you use the Invaio Sites. Personal data is information that identifies you or can be used to identify or contact you, such as your name, address, email address and telephone number and any information about you that is directly linked to such data. We collect the personal data that you submit to us, as well as the information that is collected from the use of cookies on our website. Such information may be held on our contacts and administration databases either because of the work we have done with you or are currently engaged in, or because we believe you might be interested in receiving material from us about our business, products, programs and services. This allows us to manage our relationship with you efficiently, improve our site and the services which we offer to you and to target items of interest we may send to you.

Non-personally identifiable information is also collected and refers to information that is statistical in nature only and that does not, by itself, allow to identify a specific individual or entity, and which depends upon the visiting you do on the site. For example, this information may include the domain from which you access the internet, the date and time you access the site, and the internet address of the website from which you linked directly to the site. This information is used in an aggregate form to make the site more useful and attractive to its users.

 

Examples of Information That You Provide to Us

• Career Submissions. We collect your CV/resume and other personal data when you apply for employment opportunities on the Invaio Sites.
• Contact Information. We also collect your name, email, mailing address, and telephone number submitted on the Contact Us page on the Invaio Sites. If you communicate with or request information from us by email or on the Invaio Sites, we will have your email address as well as whatever information you choose to include in your correspondence.

 

Examples of Information We Collect About Your Use of the Invaio Sites

• When you visit the Invaio Sites, we collect information about your use of the Invaio Sites. For example, we collect your IP address, pages visited, time spent on the site, browser and device type, language and date of your visit.
• We also collect information through tracking technologies such as cookies and web beacons to help us understand how you use Invaio’s site and enable us to personalize your experience. These technologies help remember your preferences and allow us to bring you the content and features that are likely to be of greatest interest to you.
• We may collect content or contributions you post in a public space on the Invaio Sites or other publicly available resources like social media campaigns. This includes comments, videos and photos that you might submit. If you contact us through a social media site, we may collect your social media identifier.
• We collect geographical data included in communication and content that you have submitted and from emails you receive from us that may also track which emails are opened and which links are clicked by recipients.

 

II. How Do We Use Your Information and On What Legal Bases?

We use your personal data to contact you when you give us your consent to do so. In addition, as permitted under applicable data protection laws, Invaio collects, uses, and processes your personal data for complying with legal or regulatory obligations of Invaio, or for the legitimate interest of Invaio’s business. We process your personal data where we have legitimate interests or a legal obligation for the following purposes:

• To submit investigational and marketed product reports as required by law
• To process your application for employment, including requesting any additional information, responding to your questions and informing you of other employment positions that may be of interest to you (through our personnel or third-party recruiters contracted on our behalf)
• To monitor, improve and administer the Invaio Sites and the services provided on the Invaio Sites
• To inform you of significant changes to this Notice
• To provide Invaio.com, our branded websites and mobile apps, and any other websites that link to this policy to you (together, the "Invaio Sites")
• To market our products
• To validate your identity
• To comply with our legal requirements
• To detect, prevent, and respond to fraud, intellectual property infringement, violations of our Terms and Conditions, violations of law, or other misuse of the Invaio Sites
• To feature and verify your story, if applicable
• To process your registration and provide services you may request

 

III. Who Do We Share Your Information With?

We share your personal data with:

• Our affiliates, which are bound to the terms of this Notice
• Any alliance partners with whom we partner with to offer certain products and services we may have and who are identified on the Invaio Sites. We share your personal data as needed for them to comply with their legal obligations with respect to those products and to understand how to effectively market and improve those products. Our alliance partners are bound by a duty of confidentiality to Invaio.
• Our collaborators and partners that provide services that support our trials and programs
• Our service providers, which are contractually obligated to provide services to us in a manner consistent with this Notice. Our service providers include:
  • vendors and suppliers that provide us with technology, services, and/or content related to better operation and maintenance of the Invaio Sites
  • our attorneys and auditors
  • vendors that provide analytics and research services
• To another third party as part of a merger, acquisition or other sale or transfer of Invaio and/or any of its affiliates

Please note that we may need to disclose your personal data if we are required to do so by law, to exercise and protect the legal rights of Invaio or its personnel and representatives, and to investigate, prevent or respond to suspected illicit activities, including fraud and threats of harm to individuals.

 

IV. Third-Party Advertising, Targeted Advertising and Social Media

Advertising - You may be provided with online advertisements of our products and services on third-party websites and mobile services that are tailored to you, for example, on the basis of information that you provide to us or a third-party website you are visiting, or of your browsing activity, purchases, or interests. These types of tailored online advertisements may come through several sources, such as the following:

• We may share with our advertising service providers your non-identifying information that we have obtained from cookies and other tracking technologies on the Invaio Sites.
• Some sites participate in online targeted advertising (this is also sometimes called re-target advertising or interest-based advertising). You can identify these sites by the “Advertising Choices” link in the footer. Our advertising network partners may place and use cookies on our websites and on other third-party website to collect information about your activities in order to provide you with online advertisements that are based on your interests. When an online targeted advertisement is delivered to you, you will see an “Ad Choices” icon. Clicking on the icon or link will take you to a website where you can manage or opt out of the use of data about your browsing history that is used for the delivery of online behavioral advertisements. If you opt out, you may still see advertisements online, including advertisements from us that are based on other information (e.g., based on the content of the page being viewed rather than your prior clickstream activity). In some cases, data may still be collected about your browsing activity by these third-party advertisers, but they will not use this data to deliver advertisements that are based on your past online browsing behavior. You can also opt out now by clicking here.
• Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. As of the effective date of this Privacy Policy, an industry standard has not yet been established on how to respond to these signals. Therefore, Invaio does not currently respond to these signals. As discussed above, you can opt-out from advertisers that use your browsing history to deliver online targeted advertisements by visiting adchoices.

Social Media - Invaio may provide the option for individuals to participate in polling activities, including through social media channels. Invaio is not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal data you disclose to other organizations through or in connection with our social media pages. Additionally, Invaio may monitor social media channels for mentions of our brand, competitors, and products, which gives Invaio an opportunity to track, analyze, and respond to conversations about us on social media.

 

V. How Long Do We Retain Your Information?

We intend to keep your personal data accurate and up-to-date and retain it for the period necessary to fulfill the legitimate business purposes or uses outlined in this Policy, unless a longer retention period is required or allowed by applicable data protection law or to otherwise fulfill a legal obligation. Precisely how long we need to keep your personal data depends on the purpose for which we collect it, and therefore there is no standard retention period. Thus, the retention period may vary depending on the circumstances. For other legal reasons, e.g. in the context of legal claims, we may need hold personal data beyond the term required to meet the defined purpose for which they were collected in the first place. However, in these cases we will no longer actively process the personal data for the originally specified purpose. In general, we do not retain the information collected on the Invaio Sites for longer than five years unless we have a need to retain it.

Should you wish to obtain more information on where and how long your personal data Personal Information is stored, and on your right of erasure please contact Invaio’s Data Protection Officer who can be reached at [email protected].

 

VI. Cookies and similar technologies

Cookies are small text files that are stored on the browser of your computer that assign an anonymous identifier to your browser and provide information to the cookie sender. We use "cookies" and other web technologies to collect information, support certain features of our sites, make it easier for you to navigate the Invaio Sites and display content that is relevant to your interests. “Cookies” also provides us with information about the ways visitors use our sites – which pages they visit in what order, which links they use, and how long they stay on each page

We do this to:

• analyze and improve the effectiveness of our advertising campaigns;
• support and enhance the features and functionality of our sites – for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits to our sites; and
• personalize your experience when you use our sites.

Generally, the information we collect using these web technologies does not identify you personally. If, however, you have created a user identity, for example, by signing up to use a password-protected area on one of our sites, we may link the information we collect using web technologies to other information that identifies you personally. Most browsers automatically accept cookies by default, but if you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave a site. Although you are not required to accept our cookies when you visit our sites, if you set your browser to reject cookies, you may not be able to use all of the features and functionality of our sites

 

Google Analytics

Some of the Invaio Sites use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). The information generated by Google’s cookie about your use of the Invaio Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. You can opt-out of Google Analytics here.

 

VII. What Are Your Rights and Choices?

Your right to make informed decisions about information collection is important to Invaio. Please note that you always have the right to:

• obtain confirmation that Invaio has collected your personal data and information about how we use your personal data and/or obtain a copy of your personal data
• verify the accuracy of your personal data
• request that we correct, update, amend, delete, or transform your personal data into anonymous form
• request that we stop or restrict our use of your personal data (including opting-out of receiving emails or calls from us)
• request the portability of your personal data in a structured, commonly used and machine-readable format and to transfer this personal data to another data controller or, if technically feasible, to have it transferred by us if the legal requirements are met
• withdraw your consent where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose at any time
• object to the processing of your personal data which is necessary for the purpose of our legitimate interests, on grounds relating to your particular situation. If your personal data processed by us is for direct marketing purposes, you have the right to object to this processing at any time, without any special reason

To exercise any of these privacy rights, please contact us at [email protected]. Please know that in order for us to respond to your request we may require that you verify your identity.
If you need further assistance regarding your rights, please contact our Data Protection Officer at [email protected], and we will consider your request in accordance with applicable laws. You also have the right to lodge a complaint with your local data protection authority.

 

VIII. Your California Privacy Rights

If you are a California resident, you have certain additional rights related to information that we collect about you.

Invaio has collected the following categories of personal data from consumers within the last twelve (12) months:

• Contact Information (name, email and postal address)
• Online Identifiers (IP address, cookie IDs)
• Demographic Information (age, race, gender)
• Internet Activity Information
• Audio Information (voicemail and other call recordings)
• Professional or employment related information

 

Your California Rights

• Right to Notice. Before or at the time we collect personal data from you, you have the right to receive notice of the personal data to be collected and the purposes for which we use it. This Notice is intended to satisfy this requirement.
• Right to Know. You have the right to request that we provide you with the following
  • The categories of personal data we have collected about you;
  • The categories of sources from which we have collected personal data about you;
  • The business or commercial purpose for collecting your personal data;
  • The categories of third parties with whom we share personal data;
  • The specific pieces of personal data we have collected about you; and
  • The categories of personal data that we have disclosed about you for a business purpose.
• Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights under the California Consumer Protection Act (CCPA), including the rights listed above.

Please note that Invaio may not be required to fulfil your requests in certain circumstances. These include instances where we must retain or restrict access to personal data in order to preserve scientific integrity, as your personal data must be managed in specific ways in order for the information to be reliable and accurate and to meet regulatory obligations of Invaio and its affiliates.

Additionally, Invaio is not required to provide information in response to a request to know for a particular consumer more than twice in any given twelve-month period. When you submit a request to exercise your right of access, your right to deletion, or your right to know, we are required to verify that you are who you say you are. We may request that you provide additional personal data for the verification process.

To exercise the rights described above, to file a concern or complaint, or to opt-out of particular programs, please contact our Data Protection Officer at [email protected] or by calling +1 617-203-6816.

 

IX. International Transfer of Information

We collect and receive data from inside and outside of the United States. We will use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the EU and where required implement additional safeguards. These clauses are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of the data. We use Standard Contractual Clauses so that the data flows necessary for business take place legally. If you would like to obtain a copy please contact Data Protection Officer at [email protected].

 

X. How Do We Protect Your Personal Data?

Invaio maintains a comprehensive data security program, including commercially reasonable administrative, physical and technological security measures, to protect your personal data and to guard against unauthorized access to your personal data or against the unauthorized alteration, disclosure, destruction and/or loss of such data. In deciding what level of security is appropriate, Invaio will take into account the nature of the personal data in question, and the harm that might result from its unauthorized use, disclosure or loss.

Although we take reasonable precautions to protect the information and personal data we collect on the Invaio Sites and store in our databases, no data transmission over the Internet can be guaranteed to be 100% secure.

 

XI. Third Party Sites

The Invaio Sites feature links to third-party websites ("Third-Party Site(s)"). These Third-Party Sites are not owned or controlled by us and we are not responsible for the privacy practices of such Third-Party Sites. We encourage you to be aware when you leave the Invaio Sites. If you choose to link to a Third-Party Site, you should read the privacy policy, statement or notice of that website to understand how that Third-Party Site collects and uses personal data. This Notice does not apply to any information collected by Third-Party Sites.

 

XII. Children

The Invaio Sites are not directed to children under the age of thirteen (13), and we request that these individuals not provide personal data through the Invaio Sites. The Invaio Sites, its content, and its services are intended for individuals over the age of 13. The Invaio Sites are not directed to, nor do we knowingly collect information from, children under the age of 13. If we actually know that a user under the age of 13 has volunteered personal data on the Invaio Sites we will delete such information from our records. If you become aware that your child or any child under your care has provided us with personal data, please contact us at the contact information listed below.

 

XIII. Special Notice Regarding International Transfer of Personal Data

Invaio is a United States corporation based in Cambridge, Massachusetts, with affiliates and operations in Durham, North Carolina; Basel, Switzerland; Sao Paulo, Brazil; Milan, Italy and Madrid, Spain. Invaio uses web servers and stores data in the United States or in other countries. We may transfer your personal data to our service providers and others located in any of these countries for the purposes described in this Statement. Different countries have different privacy laws and requirements, and some provide less legal protection for your personal data than others. Please know, however, that no matter where your personal data is collected or processed, if it was collected through an Invaio Site, we will ensure that it is protected by the terms of this Policy and any privacy notices or click-through agreements that apply to you. By using this site, you are consenting to the collection, use, and transfer of your personal data in or to the United States or any other country in the world.

 

XIV. Updates and Contacting Us

We may amend this Policy at any time. Any changes to this Policy will be posted on the Invaio Sites. Should these amendments materially relate to any consents you may have given, Invaio will contact you in order to obtain your consent to any change in the use of your personal data.

If you have any questions or concerns about this Policy or our use of your personal data, please email us at [email protected] or write us at:

Invaio Sciences, Inc.
75 Moulton Street
Cambridge, MA 02138-1127 USA
Attention: Data Protection Officer