This Policy is intended to explain the conditions under which we collect, use, and disclose personal and other information in connection with the Site, and your rights in relation to that information. By visiting our Site and/or using the features made available to you on the Site, you are agreeing to the terms of this Policy.
The personal and other information that we collect about you is controlled by Spring Bank Pharma, which is headquartered in the United States at 86 South Street, Hopkinton, Massachusetts 01748.
If you do not want us to collect, use and share your personal information as described in this Policy, please do not provide us with any of your personal information.
INFORMATION WE COLLECT
We may collect several types of information from visitors to the Site.
Voluntarily submitted personal information. For purposes of this Policy, “Personal Information” is information that we can directly associate with a specific person’s identity, alone or with the aid of additional information. You can visit the Site without submitting any personal information. However, if you send us an email or submit information in an interactive portion of the Site, then you may voluntarily provide personal information to us. For example, when you sign up to receive company press releases and alerts via email, you will be asked to provide us with certain personal information, such as your first name, last name, and email address. We may combine personal information with other information that we or third parties collect about you in other contexts. If so, we will treat such combined information as personal information and protect it in accordance with this Policy.
Automatically collected usage information. Like most websites, we use automatic data collection technology when you visit the Site to record information that identifies your computer, track your use of the Site, and collect certain basic information about you and your browsing habits. This information (collectively “Usage Information”) includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the Site.
This automatic data collection may be performed directly by us or on our behalf by our service providers.
Web log data. When you use the Site, we may automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see “Cookies,” below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.
Pixel tags. The Site or the emails that you receive from Spring Bank Pharma may use an application known as a “web beacon” (also known as a “clear gif,” “web beacon,” or “web bug”). A pixel tag is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it allows an email sender to determine whether a user has opened a particular email.
Third party analytics. We also may partner with certain third parties to collect, analyze, and use some of the personal and non-personal information described in this section. For example, we may allow these third parties to set cookies or use web beacons on the Site or in email communications from Spring Bank Pharma. This information may be used for a variety of purposes, including online behavioral advertising, as discussed below (see the section entitled “How we share information with third parties”).
HOW WE USE YOUR INFORMATION
Spring Bank Pharma uses the information that we collect for a variety of purposes.
If we have personal information about you, we may use it to respond to your questions or requests concerning the Site or other services offered by us or by our partners; to fulfill the terms of any agreement you have with us; to fulfill your requests for our services or otherwise complete a transaction that you initiate; to send you information about our services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications; to deliver confirmations, account information, notifications, and similar operational communications; to improve your user experience and the quality of our products and services; to comply with legal and/or regulatory requirements, including court orders and subpoenas; to assert or defend our legal rights or property or the property or rights of others; to manage our business; to improve or customize the Site or the user experience; and, as otherwise specifically, described in this Policy.
We use the non-personal information that we collect for purposes including: counting and recognizing visitors to the Site; analyzing how visitors use the Site and various Site features; improving the Site and enhancing users’ experiences with the Site; creating new products and services or improving our existing products, services and customer experience on the Site; enabling additional website analytics and research concerning the Site; and managing our business. We may link non-personal information gathered using cookies and web beacons, or from other sources, with personal information. But in that event, we will treat the combined information as personal information.
We also may use the personal and non-personal information that we collect to send you promotional communications, including emails or postal mail about the products and services offered by spring Bank Pharma or our partners. Although we hope you will find our promotional emails of interest, you may opt out of receiving them by sending an email to email@example.com with “opt out” in the subject line. Promotional emails will also have instructions for opting out of that type of communication in the future.
HOW WE SHARE INFORMATION WITH THIRD PARTIES
We share your personal information and non-personal information with other parties for a variety of purposes, as described below.
Third party online tracking. We partner with certain third parties to collect the non-personal information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of Google Analytics cookies here. If you prefer to prevent all or some third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Our Site currently does not respond to “do not track” browser headers, but you can limit tracking through these third-party programs by taking the steps described above.
Third-party service providers and business partners. Spring Bank Pharma also uses other third-party service providers to host and manage the Site, and for other Spring Bank Pharma business activities. These service providers may collect and/or use your information to assist us in achieving the purposes discussed above in the section entitled “How we use your information.” For example, we may use third parties to help us target and implement our email communications and direct mailings. We also use third-party platforms to help us manage our relationships with our customers, prospective customers, and research partners.
We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
Legal purposes. We may use or share your personal or non-personal information with third parties when we believe, in our sole discretion, that doing so is necessary:
- to comply with applicable law or a court order, subpoena, or other legal process;
- to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
- to establish, protect, or exercise our legal rights or defend against legal claims; or
- to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
Aggregated information. From time to time, we may also generate and share anonymous and aggregated information about Site users, such as reports on trends in the usage of our Site, the overall number of Site visitors, and the number of times that individual pages on our Site are viewed.
We may share your information as needed to enable a third party contractor or service provider to conduct on our behalf any activities that we could otherwise perform directly. We require such third parties to maintain the confidentiality of such information and permit their use of such information only as necessary to provide us with specified services.
HOW WE PROTECT YOUR INFORMATION
We employ commercially reasonable physical, electronic, and procedural safeguards to protect the information that we maintain from loss, misuse, unauthorized access, use, modification, disclosure, alteration, or deletion. However, no security system is impenetrable, and we can neither guarantee the security of our databases, nor guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, email sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
If you want to view the information, if any, that we have about you, or if you wish to revise or delete a specific category of information from our records, you may contact us by email at firstname.lastname@example.org. If you wish to stop receiving commercial e-mails from us, please unsubscribe by following the instructions in the email that you receive, or by emailing your opt-out request to: email@example.com.
Our Site contains links to external websites that are maintained by third parties. We have no control over those other sites, and we are also not responsible for the collection, use or sharing of information by the operators of these external sites, which are subject to their own privacy policies and terms of service. This Policy does not apply to any such other websites that may be accessed from our Site.
IMPORTANT NOTICE TO USERS OUTSIDE OF THE UNITED STATES
The information that we collect through or in connection with the Site is transferred to and processed in the United States for the purposes described above. We may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site or by providing any personal or non-personal information to us, you expressly consent to such transfer and processing. The Site is operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information, you consent to this transfer.
The Site is not directed to children under the age of 13, and we will never knowingly collect identifying information from anyone we know to be under the age of 13. If you are under 13 years of age, do not submit any Personal Information through the Site.
HOW TO CONTACT US
© 2016 Spring Bank Pharmaceuticals, Inc. All rights reserved.