Privacy Policy
PRIVACY CHARTER
Data Controller and Data Protection Officer

1.1. In this privacy statement, InoKura S.A. , headquartered at Avenue Hippocrate No. 15, 4000 Liège (hereinafter: “InoKura S.A.” or “we”), explains how it manages your personal data as a “data controller.” This privacy statement applies to the processing of personal data by InoKura S.A. for customers, potential customers (prospects), and natural persons who contract with InoKura S.A. in any other manner as a buyer or supplier. InoKura S.A. has an establishment unit and can be contacted by email at the address mentioned in point 7.4.

1.2. All information regarding an identified or identifiable natural person constitutes personal data. This refers to information that can reasonably be linked to an individual.

1.3. The Data Protection Officer can be contacted by email at: philippe.robert@themis-security.be.

Personal Data We Process

2.1. InoKura S.A. may collect your personal data in several ways. We process personal data that you provide to us when you contact us, enter into a contract, or participate in an activity or use our services, and when you directly or indirectly provide us with data or allow us to record data about your interests, behavior, and preferences (cookies).

Information You Provide to Us

2.2. If you submit a request to InoKura S.A. , for example via the website, we require the following personal information:

a) Personal identification data (name, surname);
b) Electronic identification data (email address and other contact details);
c) Other information that may be relevant to your request, such as your activity or other additional options.

2.3. If you enter into a contract with InoKura S.A. or are a volunteer, we require the following personal information:

a) Personal identification data (name, surname, address);
b) Electronic identification and contact data (phone number and email address);
c) Company number;
d) Financial data;
e) Medical data.

These personal data must be provided directly to InoKura S.A.. If you do not provide the “mandatory” information (which varies depending on the type of contract), we may not be able to provide the requested service or enter into the contract.

Information About Your Use of Our Services and/or Products

2.5. If you use the services offered by InoKura S.A. or enter into a contract with us, we process data whose primary purpose is to conduct tests on healthy volunteers and/or small groups of patients to evaluate the tolerance, metabolism, and effectiveness of new drugs or active molecules (dietary supplements, etc.) in humans (men and women).

Legal Basis and Legitimate Interests

We process personal data based on the following legal grounds:

a) Consent of the data subject;
b) Performance of a contract with you or pre-contractual measures;
c) Legal obligation;
d) Legitimate interest of InoKura S.A..

We process personal data under legitimate interest when we use your data to provide services and content, related products, and services. Our legitimate interests include, for example: communication, IT management and security, research and analysis of our own products or services, business management, legal matters, internal management, and sharing with our affiliates.

Purposes for Which We Process Personal Data

4.1. InoKura S.A. processes personal data for the following purposes:

• As part of a service contract you enter into with InoKura S.A.;
• Maintaining customer relations (including maintaining a direct relationship between InoKura S.A. and financial services related thereto, including for the performance of a contract and pursuit of legitimate interests);
• Recruiting volunteers who meet the inclusion criteria for clinical trials;
• Processing and evaluating applications for authorizations, certificates, approvals, or other types of permissions;
• Recording notifications of manufacturing, distribution, or export of medical devices;
• Recording, evaluating, and analyzing reports of adverse drug reactions and adverse events or incidents involving medical devices;
• Conducting controls and inspections;
• Providing (scientific) advice and information in InoKura S.A.’s area of expertise;
• Selection procedures for recruiting new staff;
• Managing data related to external experts that InoKura S.A. may call upon;
• Managing information on suppliers who provide services to InoKura S.A..

Third Parties Involved in Processing

5.1. In some cases, InoKura S.A. shares personal data with third parties who are independent “data controllers.” We explain below when this is the case and why. InoKura S.A. may share data with:

a) InoKura S.A.’s service partners, for the performance of a contract or pursuit of legitimate interests;
b) Third parties to whom we are legally obliged or authorized to provide data;
c) Third parties if we suspect a violation of third-party rights, criminal offenses, or abuse, if they have a legitimate interest, or if they are public authorities. This may also include authorities such as the police, public prosecutors;
d) Parties that assist InoKura S.A. in its services and are not data processors for the pursuit of its legitimate interests;
e) Buyers or (potential) investors, for legitimate economic and commercial purposes (such as the sale of business activities or shares or a reorganization);
f) Parties that assist InoKura S.A. in developing (direct) marketing activities in pursuit of its legitimate interests.

5.2. The communication of personal data to the above-mentioned third parties will only take place if authorized under applicable laws and regulations.

5.3. InoKura S.A. also uses third-party services that act as “processors” (e.g., hosting service providers, certain software providers, mobility service providers, or parties that organize or conduct actions or surveys for us). With these providers, InoKura S.A. is required to enter into a processing agreement stating that they only process personal data according to our instructions and under our control. The list of these processors is available upon request by email at the address mentioned in point 7.4.

5.4. Currently, we do not store personal data outside the European Union. If personal data is deliberately communicated outside the European Union, we will take additional safeguards such as entering into a European Union standard contract.

5.5. Our websites may contain references and/or hyperlinks to one or more third-party websites. InoKura S.A. is not responsible for how these third parties handle personal data. We recommend that you read the privacy statement of these websites to understand and control how they handle your personal data.

Marketing, Profiling, and Cookies

6.1. We and third parties automatically collect certain information about your activity history on our website and on third-party applications using automated means, such as cookies, according to the preferences you have provided. Through certain cookies and similar technologies, unique cookie IDs or other identifiers are assigned or collected. In this way, data may be collected while you use the website or applications, or when they operate in the background on your device. We may combine them with other information about you or your device, such as an IP address. If we need consent for this, we will ask you before proceeding with this processing.

6.2. We invite you to read our cookie statement for more information on the cookies and similar technologies used and on setting your preferences.

Your Rights, Including Your Right to Object

7.1. You have the right to know what personal data we have recorded about you and to whom we have communicated your personal data.

7.2. Furthermore, you have the right to request, subject to applicable law, to correct, update, delete your personal data, restrict the processing of your personal data, or to provide your personal data in a structured, commonly used, and machine-readable format to transfer it to another company.

7.3. We are required to draw your attention to your absolute right to object to direct marketing and your rights (i) to object to any processing, including profiling, carried out for the pursuit of InoKura S.A.’s or a third party’s legitimate interests and (ii) to file a complaint with a data protection authority. In Belgium, this is the Commission for the Protection of Privacy, designated as the Data Protection Authority.

7.4. Rights of access, rectification, restriction of processing, erasure, or data portability, as well as withdrawal of consent, can be exercised free of charge by email, form, phone, or mail at the following addresses or numbers:

• Email: info@inokura.be
• Phone: +32 (0)4 323 83 11
• Mail: InoKura S.A. / Clinical Pharmacology Unit
  CHU Sart-Tilman, Building B35, Tower 2,
  Avenue de l’Hôpital, 1
  4000 Liège

Security

8.1. We have taken appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing.

8.2. If you believe that your data is not properly secured or if you have evidence of improper or irregular use of your personal data, please contact our customer service at the email address mentioned in article 7.4.

Retention Period

We only retain personal data for as long as necessary for the purposes for which they were obtained unless we are legally required to retain personal data longer or if this appears necessary for managing a potential dispute.

Modification

10.1. We reserve the right to unilaterally modify or supplement this privacy statement. We will inform you of any changes to the extent possible. We advise you to periodically review our privacy statement.

10.2. This privacy statement was last updated on May 25, 2018.

Contact/Questions

11.1. For questions or comments regarding this privacy statement and/or the processing of personal data, you can contact us at the addresses or numbers mentioned in point 7.4 above.