Privacy Policy

Effective as of March 15, 2021
Last Updated: March 15, 2021

SwanBio Therapeutics, Inc., (collectively “SwanBio”, “Swan”, “us”, “we” or “our”) recognizes and respects the privacy rights of individuals with regards to their personal data. This Privacy Policy explains what types of personal data SwanBio may collect from you and how we use it. This Privacy Policy also explains the policies and practices that we have developed to safeguard personal data and to comply with applicable data protection laws. Please read this Privacy Policy carefully to understand what personal data we collect, how we collect it, how we use it, who we may disclose it to, and how you can manage your personal data.

Information We Collect

When you interact with us through the Website, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Website

We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to this Website, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of SwanBio and the authorized third parties referred to herein.

Other Information

Non-Identifiable Data: When you interact with SwanBio through the Website, we may receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. SwanBio may store such information itself or such information may be included in databases owned and maintained by SwanBio affiliates, agents, service providers, or business partners. This Website may use such information and pool it with other information to track, for example, the total number of visitors to our Website, the number of visitors to each page of our Website, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.

In operating this Website, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Website gives to your browser when you access the Website. Our cookies help provide additional functionality to the Website and help us analyze Website usage more accurately. For instance, our Website may set a cookie on your browser that allows you to access the Website without needing to remember and then enter a password more than once during a visit to the Website. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Website’s features.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of our services, we may often conduct research on customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and SwaBio may share this aggregate data with its affiliates, agents, service providers, and business partners. This aggregate information does not identify you personally. SwanBio may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Our Use of Your Personal Data and Other Information:

SwanBio uses the Personal Data you provide, if any, in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to SwanBio services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. SwanBio may also use your Personal Data and other personally non-identifiable information collected through the Website to help us improve the content and functionality of the Website, to better understand our users and to improve our services. SwanBio and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. By providing us with any contact information, whether it be email, telephone, text number, mobile telephone number, fax, social media account, physical address, or any other method, you consent that we may use such method and contact information to communicate with you.

Our Disclosure of Your Personal Data and Other Information:

SwanBio uses various security and other measures to protect your Personal Data. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies: We may also share your Personal Data with our affiliates for purposes consistent with this Privacy Policy.

Agents, Business Partners, Consultants and Related Third Parties: SwanBio, like many businesses, sometimes hires other persons and companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another company to perform a function in the ordinary course of business, we may share information, including Personal Data, with them to the extent such information is needed to perform their specific function.

Legal Requirements: SwanBio may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary or desirable in our business judgement to (i) comply with a legal obligation, (ii) protect and defend the rights or property of SwanBio or its affiliates, (iii) act in urgent circumstances to protect the personal safety of users of the Website or the public, or (iv) protect SwanBio or its affiliates against legal liability.

Your Choices:

You can use the Website without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain services from SwanBio.

Exclusions:

This Privacy Policy does not apply to any Personal Data collected by SwanBio other than Personal Data collected through the Website. This Privacy Policy shall not apply to any unsolicited information you provide to SwanBio through this Website or through any other means. This includes, but is not limited to, information posted to any public areas of the Website, such as bulletin boards (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be public and non-confidential and SwanBio shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution in perpetuity.

California Residents:

California Code Section 1798.83 permits individual California residents to opt out of SwanBio’s disclosure of personal data to third parties for their direct marketing purposes. California law also permits residents of California to request and obtain from us once per year, free of charge, a list of the third parties (if any) to whom we have disclosed personal data for their direct marketing purposes in the prior calendar year, as well as the type of personal data disclosed to those third parties. SwanBio does not disclose your personal data to third parties for their direct marketing purposes. If SwanBio changes this practice, we will update this section. Please contact us with questions.

Your Rights to Request Access to and Deletion of your Personal Information (“PI”): Under the California Consumer Privacy Act (“CCPA”), California consumers (both customers and employees), subject to certain exceptions, have the right to request access and deletion of PI collected, used, transferred, disclosed, sold, or processed by SwanBio. You can make such a request by submitting a request via email at privacy@swanbiotx.com. Please include your full name, mailing address, email address, phone number, date of birth (month, day), relationship to SwanBio (e.g., former employee, health care provider, patient in a clinical trial), and type of request (e.g., Request to Know/Access, Request to Delete).

If you request deletion of your PI, we will assess the request to confirm whether there are any reasons for which we are required to retain the information about you, including for specific business purposes, to fulfil a legal obligation, or other reasons permitted under the law. If we are not able to service your deletion request, we will provide you with an explanation.

We Do Not Sell Your Personal Information: Under the CCPA, California consumers have the right to request that their information not be sold for value. Currently we do not and will not sell or disclose your information to third parties for monetary or in-kind compensation; however, if this practice changes in the future, we will provide updated information via this Privacy Policy and provide instructions on this page on how to submit a request to stop selling your PI. In that event, you may also request, free of charge, a list of the third parties (if any) to whom we have disclosed your PI for direct marketing purposes within the prior calendar year, as well as the type of PI disclosed to those third parties.

Children:

SwanBio does not knowingly collect Personal Data through the Website from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Website. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on this Website without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to SwanBio through this Website, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites:

This Privacy Policy applies only to the Website. This Website may contain links to other websites not operated or controlled by SwanBio (the “Third Party Websites”). The policies and procedures we described here do not apply to the Third Party Websites. The links from this Website do not imply that SwanBio endorses or has reviewed the Third Party Websites. We suggest contacting those sites directly for information on their privacy policies.

Social Media:

Through the Website, you can choose to access certain social media websites and services that are owned and/or controlled by third parties (including, without limitation, Facebook and Twitter) (such websites and services, collectively, the “Social Media Services”). When you elect to access and use the Social Media Services, you may be sharing your information (which will include personal information if you elect to share such information) with those Social Media Services. As with other Third Party Websites, the information that you share with the Social Media Services will be governed by the privacy policies and terms of service of the providers of such Social Media Services and not by the policies and procedures we describe here. You may also be able to modify your privacy settings with these Social Media Services to, for example, control what information the Social Media Services disclose to other entities, including SwanBio. When you log in to your Social Media Services account through the Website, we will collect relevant information necessary to enable the Website to access that Social Media Service, however you will provide your login information, like your password, directly to such Social Media Service (and not to SwanBio). As part of such integration, the Social Media Service will provide SwanBio with access to certain information that you have provided to such Social Media Service, and we will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of such Social Media Services. However, please remember that the manner in which Social Media Services use, store and disclose your information is governed by the policies of the applicable Social Media Services provider, and, as a result, SwanBio shall not have any liability or responsibility for the privacy practices or other actions of Social Media Services that may be enabled within and/or otherwise accessible through the Website.

Security:

SwanBio takes reasonable steps to protect the Personal Data provided via the Website from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from this Website may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to SwanBio via the Internet. SwanBio is not liable for the illegal actions of any third party (for example, criminal hackers).

Other Terms and Conditions:

Your access to and use of this Website is subject to the Terms of Use.

Changes to SwanBio Privacy Policy:

The Website and our business may change from time to time. As a result, at times it may be necessary for SwanBio to make changes to this Privacy Policy. SwanBio reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Such changes will be posted on this page or a similar page of the website. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Website after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information; Contacting SwanBio:

If you have provided any Personal Data, in order to keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via this Website.

Please feel free to contact us if you have any questions about SwanBio’s Privacy Policy or the information practices of this Website at: privacy@swanbiotx.com.