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REGnosys Privacy Statement

1.
OUR APPROACH TO PRIVACY

1.1
REGnosys Limited (“REGnosys”, “we”, “our”, or “us”) is committed to protecting your privacy. This Privacy Statement sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information”) and information regarding our use of cookies and similar technologies.
1.2
REGnosys operates the www.regnosys.com website (the “REGnosys Site”) and the www.rosetta-technology.io website (the “Rosetta Site”), from which you can access a platform operated by us that hosts various tools, visualisations and other content (the “Content Platform”). This Privacy Statement applies to the REGnosys Site, the Rosetta Site (the “Sites”) and the Content Platform.
1.3
Please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this Privacy Statement.
1.4
REGnosys is the data controller of the personal information we hold about you. If you have a question about this Privacy Statement or how we use your personal information, please contact us using the details set out in the Contact Us below.

2.
PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

2.1
We collect personal information about you when you voluntarily submit information directly to us when you access or use the Sites or the Content Platform. This can include information you provide to us when you register for an account, fill in a form, correspond with us via the Sites or Content Platform, via email or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to surveys or use some other feature of the Sites or Content Platform as available from time to time.
2.2
If you choose not to provide personal information, we may not be able to provide you with some elements of the Content Platform or respond to your other requests.

Information you provide to us

2.3
The table below sets out the categories of personal information we collect about you when you use the Sites, how we use that information and the corresponding legal basis which we rely on to process the personal information.
Category of information How we use it Legal basis for processing
Contact information and basic personal and professional details. Such as your name, institution name, e-mail address. We use this information to communicate directly with you to respond to any queries you submit to us. This processing is necessary for our legitimate interests, namely, administering the Sites and communicating with you in connection with those questions, issues and concerns.
We use this information to send you news, alerts and marketing communications in accordance with your preferences. We will only process your personal information in this way to the extent you have given us consent to do so.
Correspondence, comments and feedback. When you contact us directly, e.g. by email, when you respond to user surveys or when you provide feedback to us, we will record your comments and opinions. We use this information to monitor and improve the Sites, and our business and to help us develop new products and services. The processing is necessary for our legitimate interests, namely to administer and improve the Sites and our business.
To address your questions, issues and concerns and to resolve your issues with the Sites. This processing is necessary for our legitimate interests, namely, administering the Sites and communicating with you in connection with those questions, issues and concerns.
2.4
The table below sets out the categories of personal information we collect about you when you use the Content Platform, how we use that information and the corresponding legal basis which we rely on to process the personal information.
Category of information How we use it Legal basis for processing
Contact information and basic personal and professional details. Such as your name, country, state, institution name, institution type, role, job title, intended use, email and password. We use this information to operate, maintain and provide to you the features and functionality of the Content Platform, including authentication and authorisation purposes. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely the REGnosys Terms of Service).
We use this information to communicate directly with you to respond to your queries (for example, support requests) and to send service-related emails (for example, account verification or technical and security notices). This processing is necessary for our legitimate interests, namely, administering the Content Platform and communicating with you in connection with the Content Platform.
We use this information to send you news, alerts and marketing communications in accordance with your preferences. We will only process your personal information in this way to the extent you have given us consent to do so.
We use this information to monitor and improve the Content Platform and our business and to help us develop new products and services. The processing is necessary for our legitimate interests, namely to administer and improve the Content Platform and our business.
Correspondence, comments and feedback. When you contact us directly, e.g. by email, when you respond to user surveys or when you provide feedback within the Content Platform, we will record your comments and opinions. We use this information to monitor and improve the Content Platform, and our business and to help us develop new products and services. The processing is necessary for our legitimate interests, namely to administer and improve the Content Platform and our business.
To address your questions, issues and concerns and to resolve your issues with the Content Platform. This processing is necessary for our legitimate interests, namely, administering the Content Platform and communicating with you in connection with those questions, issues and concerns.
User-generated data. Certain features, allow users to create data, some of which may include personal information. We use this information to operate, maintain and provide to you the features and functionality of the Content Platform, namely to allow you to generate and retrieve certain data. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely the REGnosys Terms of Service).

Information we collect from you automatically

2.5
We also automatically collect personal information about you indirectly about how you access and use the Sites or the Content Platform.
2.6
The table below sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
Category of information How we use it Legal basis for processing
Information about the way you access and use the Sites or the Content Platform. For example, the actions you take and how you interact with the user interface or features of the Sites or Content Platform, pages you have visited and information related to your session. We use this information to monitor and improve the Sites and Content Platform. The processing is necessary for our legitimate interests, namely to improve the Sites, the Content Platform and our business generally, to monitor and resolve issues and for other internal purposes.
Content Platform metadata. For example, data relating to successful and attempted logins and password resets. We use this information to monitor the Content Platform, and for other internal purposes such as security. The processing is necessary for our legitimate interests, namely to monitor and resolve issues and for other internal purposes.
Technical information about your device and its software, such as your IP address, browser type, Internet service provider, operating system, date and time stamp, and other such information. We use this information to present the Sites and Content Platform to you on your device and to enhance and personalise your experience. The processing is necessary for our legitimate interests, namely to tailor the Sites and Content Platform to our users.
We use this information to monitor and improve the Sites and Content Platform. The processing is necessary for our legitimate interests, namely to improve the Sites, the Content Platform and our business generally, to monitor and resolve issues and for other internal purposes.
2.7
We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
2.8
We may anonymise and aggregate any of the personal information we collect (so that it does not identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Sites and Content Platform and developing new products and features. We may also share such anonymised information with others.

3.
DISCLOSURE OF YOUR PERSONAL INFORMATION

3.1
As required in accordance with how we use it, we will share your personal information with the following categories of recipients:
  1. ISDA. When you create an account on the Content Platform, we will share this information with the International Swaps and Derivatives Association, Inc (“ISDA”) in connection with the provision of some of the tools and content on the Content Platform. When you use these tools and content, the information you upload will also be available to ISDA. Please see ISDA’s Privacy Notice (at https://www.isda.org/general/isda-member-and-non-member-representative-privacy-notice/) for information about how ISDA will use your personal information.
  2. Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include hosting, mailing or email services, data enhancement services, fraud prevention, or providing analytics services.
  3. Purchasers and third parties in connection with a business transaction. Personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
  4. Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce the REGnosys Terms of Service or to protect the security or integrity of the Sites and/or Content Platform; and/or (c) exercise or protect the rights, property, or personal safety of REGnosys, our customers or others.
3.2
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

4.
MARKETING AND ADVERTISING

4.1
We may send you emails from time to time with relevant information about REGnosys, our services and promotional materials about third parties which we think you will find interesting. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you.
4.2
If you do not want to receive such messages from us, you can usually inform us by selecting certain boxes when you provide your contact details to us. You can also change your marketing preferences by clicking on the unsubscribe link at the bottom of our emails.

5.
STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

5.1
Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting providers on secure servers.
5.2
International transfers of your personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the European Economic Area (“EEA”), Switzerland or the UK, your personal information may be processed outside of the EU including in the United States; these international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out in the Contact Us section below.
5.3
Retention of your information: We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.
5.4
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.

6.
YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

6.1
In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
  1. Right of access and portability. The right to obtain access to your personal information along with certain related information, and to receive that personal information in a commonly used format and to have it transmitted to another controller.
  2. Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
  3. Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
  4. Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
  5. Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.
6.2
If you wish to exercise one of these rights, please contact us using the details set out in the Contact Us section below.
6.3
You also have the right to lodge a complaint to your local data protection authority. If you are based in the EU, information about how to contact your local data protection authority is available at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

7.
COOKIES AND SIMILAR TECHNOLOGIES

7.1
We use cookies to distinguish you from other users. This helps us to provide you with a good experience when you use the Sites and Content Platform, and allows us to improve the Sites and Content Platform. A cookie is a small data file that we transfer to your device’s hard disk (such as your computer or smartphone) for record-keeping purposes.
7.2
We use the following types of cookies:
  1. Strictly necessary cookies. These are cookies that are required for the essential operation of the Sites or Content Platform, such as to authenticate users and prevent fraudulent use.
  2. Analytical/performance cookies. They allow us to recognise and count the number of visitors to our Sites and/or the Content Platform and to see how visitors / users move around our Sites and the Content Platform when they are using it. This helps us to improve the way our Sites and the Content Platform works, for example, by ensuring that users are finding what they are looking for easily.
  3. We may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the services and to understand more about the demographics of our visitors/users. You can learn more about Google’s practices at https://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
  4. Functionality cookies. These are used to recognise you when you return to our Site and enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
7.3
The cookies we use are designed to help you get the most from the Sites and Content Platform, but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of the Sites or Content Platform. These settings will typically be found in the “options” or “preferences” menu of your browser. To understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.
  1. Cookie settings in Internet Explorer
  2. Cookie settings in Firefox
  3. Cookie settings in Chrome
  4. Cookies settings in Safari web and iOS.
7.4
If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative’s online sources at www.networkadvertising.org.

8.
LINKS TO THIRD PARTY SITES

The Sites and Content Platform may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

9.
OUR POLICY TOWARDS CHILDREN

The Sites and Content Platform are not directed at persons under 16 and we do not knowingly collect personal information from children. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

10.
CHANGES TO THIS PRIVACY STATEMENT

We may update this Privacy Statement from time to time and so you should review this page periodically. When we change this Privacy Statement in a material way, we will update the “last modified” date at the end of this Privacy Statement. Changes to this Privacy Statement are effective when they are posted on this page.

11.
CONTACTING US

11.1
You can contact us with any query related to this Privacy Statement by going to the Contact Us page on the Site and using the Contact Form as instructed.
11.2
This Privacy Statement was last modified on 23rd March 2019.