30 June 2021
Gyroscope Therapeutics Limited respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you as to how we use and disclose your personal data when you visit our websites, or that of any affiliate of Gyroscope Therapeutics Limited (regardless of where you visit it from), and when we process your personal data for other purposes. It also sets out your privacy rights and how the law protects you.
This Privacy Notice applies in particular to all Gyroscope Therapeutics Limited online services activities, including, but not limited to www.gyroscopetx.com and www.orbitsds.com, or other websites (“Services”) in which it is posted or linked to.
IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY NOTICE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.Alternatively, if you do not agree with part of this privacy notice relating to cookies, you can change your privacy settings to limit some access to our processing data. This can be done via our Cookie Notice. Please also refer to the “Your Legal Rights” section below, which sets out your further options.
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how Gyroscope Therapeutics Limited, or any affiliate, collects and processes your personal data through your use of the Sites or any affiliate site using this Privacy Notice, including any data you may provide through the Sites, together with other processing activities that we may need to undertake, and which are not covered by separate specific privacy notices.
The Sites are not intended for use by anyone under the age of 18, and such individuals may not use the Sites. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), we do not collect Information from people we actually know are under 13 years of age, and no part of the Services is designed to attract people under 13 years of age. If we later learn that an individual has provided us with their information through the Website and they are under 13 years of age, we will take steps to remove that User’s personal data from our databases and to prevent the User from utilizing the Services. It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.
As described in this Privacy Notice, we may use and disclose your information to provide you with products, services and information and to improve your experience using those products and services. By using the Services, or any other Website, online service or mobile application where this Privacy Notice is posted or linked to, you acknowledge that we will collect, use, disclose, and store information as described in this Privacy Notice.
Gyroscope Therapeutics Limited is the controller and responsible for your personal data (referred to below as “Gyroscope”, “we”, “us” or “our” in this Privacy Notice).
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: Gyroscope Therapeutics Limited
Data Protection Officer: Prettys Solicitors LLP
Email address: email@example.com
Postal address: Prettys Solicitors LLP, Elm House, 25 Elm Street, Ipswich, Suffolk, IP1 2AD
Telephone number: 01473 298221
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If you are in the European Union, you may address privacy-related inquiries to our EU representative pursuant to Article 27 GDPR:
EU-REP.Global GmbH, Attn: Gyroscope Therapeutics
Hopfenstr. 1d, 24114 Kiel, Germany
Changes to your personal data
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.
The Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our sites, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes your name.
- Contact Data includes your address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, 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 the Sites.
- Usage Data includes information about how you use our Websites, products and services.
We also collect, use and share anonymised aggregated data such as statistical or demographic data for any purpose. This data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
Generally, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and biometric data) using the Sites. Nor do we collect any information about criminal convictions and offences. There is a limited exception to this general principle, in that we collect certain information for the purposes of enquiries you may make about our products and services. Where we ask for this information we will ask for your specific consent first.
As we have set out above, this Privacy Notice also applies to personal data that is processed other than via our Sites. This will include in particular individuals with whom we have contact for the purposes of keeping them apprised of our products and services, or developments within Gyroscope Therapeutics Limited. This includes healthcare professionals and related external experts and specialists. The type of personal data that we may collect and process about such individuals includes:
- Contact details, including the details of the academic or healthcare institution at which they are based;
- Details of qualifications, offices held, areas of research undertaken, publications and career history; and
- Details of our interactions, including emails or correspondence sent, and contact notes or other records of interactions.
This Privacy Notice also applies to personal data that we may process about other individuals with whom we have contact. This includes: individual suppliers, or contacts within corporate suppliers. In such cases we will keep contact details, copies of correspondence and similar data relating to historic or potential transactions.
If you fail to provide personal data
Where we need to collect personal data by law, or to provide any services to you, and you fail to provide that data when requested, we may not be able to provide that service to you.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Usage Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you request that we make contact with you.
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks; and
- search information providers.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- In order to provide you with the Services.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- To assist us when entering into or performing contracts with you.
- When communicating with you, including via email, ‘phone and SMS, and fax.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to receiving third-party marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data based on more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To administer and protect our business and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
(a) Necessary for our legitimate interests (for example, for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may receive marketing communications from us if you have requested information from us or if you have otherwise provided us with your details and, you have provided your consent for us to do so or it is lawful and in our Legitimate Interests to use your personal data in this way.
We will get your express opt-in consent before we share your personal data with any company outside Gyroscope Therapeutics Limited for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of Privacy Notice
We will only use and disclose your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use or disclose it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you, either directly or by way of an update to this Privacy Notice which is posted on our Sites, and we will explain the legal basis which allows us to do so or, where we are so required, obtain your consent before materially changing the manner in which we use and disclose your personal information. We will from time to time make changes to this Privacy Notice, and so we recommend that you revisit it on each visit to this or any affiliated site.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Other companies within our group of companies, either acting as joint data controllers or as processors and who are based in the United Kingdom or United States of America.
- External Third Parties as set out in the Privacy Notice
- Specific third parties such as Bamboo HR, who provide us with recruitment-related services, and Medpace, who provide us with clinical research services,
- 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 (unless prohibited by law), or in materially different ways only with an appropriate legal basis and/or with consent, and upon providing notice to you.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only allow our third-party service providers to use your personal data for our purposes, or as permitted or required by law, and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within our group. As this is a global group, we may share data amongst different parts of that group where it is necessary and appropriate to do so. This may mean that your data is transferred outside of the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that one of the legally prescribed safeguards is in place.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to attempt to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including, without limitation, for the purposes of providing the Services to you and 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 unauthorised 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.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are as follows:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the absolute right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
- Service providers acting as processors who provide IT and system administration services.
- HM Revenue & Customs, regulators and other authorities acting as processors or controllers based in the United Kingdom who may require reporting of processing activities in certain circumstances.
- Companies within the Gyroscope group of companies, both in the United Kingdom and in the USA.
- Information for California Residents.
California Consumer Privacy Act of 2018 (“CCPA”):
The CCPA sets forth certain obligations of for-profit businesses doing business in California that collect and sell consumer “personal information” or disclose personal data for a business purpose. Based on the definition of “business” under CCPA, we are not currently subject to the CCPA.California Civil Code Section 1798.83 (“Shine the Light Law”) permits individual California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
We do not allow third parties to advertise to Users of our Services, unless you provide consent, which is not requested in this Privacy Notice.
California Online Privacy Protection Act (“CalOPPA”)/Do Not Track:
The information we provide in this Privacy Notice is intended to comply with CalOPPA requirements.
Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Gyroscope Therapeutics Limited currently does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.