Privacy

Index

  1. Background
  2. Definitions
  3. Why do we Process your Personal Data?
  4. What Personal Data is Processed, and on what legal ground?
  5. Social media platforms
  6. Cookies
  7. How long is your Personal Data stored?
  8. Your rights
  9. Consent to the Processing of Personal Data
  10. To whom do we transfer your Personal Data?
  11. How do we protect your Personal Data?
  12. Supervision and compliance
  13. Changes to the Privacy Policy
  14. How do you contact us? 

 

  1. Background

Your privacy is important to us. This policy (“Privacy Policy”) explains how INITIATOR PHARMA A/S (“Initiator”, “we”, “us”) processes your personal data in a legal, appropriate and safe manner.

The Privacy Policy further describes when, how, and why we collect, use, transfer, and store personal data and what rights you have according to the rules in the EU’s General Data Protection Regulation (GDPR) (EU) 2016/679 with associated statutes of implementation and supplementary statutes on data protection (the “Data Protection Rules”).

The Privacy Policy applies (i) when Initiator provides its services to you as a financer, shareholder, existing or potential innovator, or other existing or potential business contact, regardless of whether you are in contact with us as a private person or as the representative for the company or organisation you work for or on behalf of, (ii) to mailings regarding events or newsletters, (iii) to other marketing events or marketing actions, (iv) to all other contacts with Initiator in connection to visits to our website www.Initiator.com (“Website”) or via social media platforms, and (vii) to requests or other contacts with us via e-mail or phone.

INITIATOR PHARMA A/S, CVR number 37663808, Ole Maaloes vej 3, DK-2200 Copenhagen Denmark, is the data controller responsible for the processing of your personal data which is carried out in accordance with this Privacy Policy.

  1. Definitions

In this Privacy Policy, the term “personal data” includes any information which can be attributable to an identified or identifiable natural person, such as e.g. name, address, personal registration number, e-mail address, phone number and photo (“Personal Data”).

This Privacy Policy describes how we Process your Personal Data. The term “processing” includes e.g. our registering, storing, transmitting, and in other ways using your Personal Data in such a manner as is described in this Privacy Policy (“Processing”).

  1. Why do we Process your Personal Data?

Initiator Processes Personal Data regarding those who in different ways come into contact with Initiator. Initiator only collects and otherwise Processes your Personal Data for the below-mentioned purposes. The overall aim of the Processing is to handle existing, former and new business relations. This entails that Personal Data is Processed in order for us to:

  • conduct our business and in other ways fulfil the agreement that has been made with you personally, your company, with your employer, or with the person, organization or company your work for or on behalf of
  • offer and enable general service and handling of business contacts, e.g. when you contact us via e-mail, telephone, social media platforms or via our Website;
  • inform and market our business through, inter alia, publishing material on our Website;
  • leave information regarding events, send out newsletters and information via post, e-mail, phone or via social media platforms; and
  • comply with applicable legislation.

What Personal Data we collect and Process depends on how you come into contact with Initiator or which relationship you have with us.

In addition to the Personal Data you provide to us, we may also collect Personal Data from third parties. These third parties vary from time to time but include inter alia suppliers of address information from public records in order to ensure we have the correct address information, and credit rating agencies or banks from where we obtain information regarding creditworthiness or information in order to conduct anti-money laundering controls.

When you are asked to provide us with Personal Data, e.g. in connection with investments in Initiator you may choose not to do so. If you choose not to provide necessary Personal Data, this may lead to us not being able to fulfil our obligations or potential obligations towards you.

  1. What Personal Data is Processed on what legal ground?

The Personal Data listed below is Processed by us for the purposed explained under section 3 above:

  • name;
  • billing and delivery address;
  • phone number;
  • e-mail address;
  • personal identification number/ ID number;
  • account number;
  • photographs of you;
  • copy of ID-documentation;
  • payment information;
  • information from police record extracts; and
  • correspondence with you.

Where the Processing of Personal Data is necessary in order for Initiator to conduct its business through provision of its services and thereby fulfil the agreement that has been entered into with you, the legal basis for the processing is GDPR article 6(1)(b). In situations where you act as a representative or contact person for a company or organisation which collaborates or has any type of business relation with Initiator, we Process your Personal Data based on GDPR article 6(1)(f), as the processing is necessary for us to pursue our legitimate interest in ensuring effective administration and communication. For this Processing, we have conducted a balancing of interests where we have, inter alia, taken into account that the Processing does not include any sensitive Personal Data and that we have a clear commercial interest in being able to provide our services to the company or organization you work for on or behalf of in an efficient manner.

For members of the board of directors, we also process your national identification number. The legal basis for such processing is the Danish Act No. 502 of 23 May 2018 on supplementary provisions to the regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the Data Protection Act), section 11(2)(1), as the processing is necessary for us to fulfill our legal obligation to register members of the board of directors with the Danish Business Authorities. Furthermore, and with the same legal basis, we also process national identification numbers when paying salaries and similar compensation, as processing of national identification number is necessary to fulfill our legal obligation to report to the tax authorities.

Where we process extracts from police records, the legal basis for this processing is section 8(3) of the Danish Data Protection Act.

Personal Data may also be used in other contacts with you, when we send you invites to events or other information. This Processing is based on our legitimate business interest of being able to provide you, as you have a business relationship with us, with relevant marketing information and other information. For this Processing we have conducted a balancing of interests where we have, inter alia, taken into account that the Processing does not include any sensitive Personal Data and that we have a clear commercial interest in being able to provide our services to the company or organization you work for on or behalf of in an efficient manner.

In the event that we intend to use your Personal Data for marketing purposes or other types of mailings or publications on our Website we will obtain your consent before any publication takes place. If the intended marketing activities are of a nature, where the related processing of personal data cannot be based on our legitimate interest in accordance with GDPR article 6(1)(f), we may contact you to also obtain your consent for such processing of your information. We will always document whether you have given your consent to our Processing of your Personal Data, and we will cease processing of your personal data if this is based on your consent and you withdraw your consent or if we for other reasons do not have a valid consent.

Some of the Personal Data which Initiator collects is Processed in order for us to comply with legal obligations according to applicable legislation, court rulings, or decisions taken by the authorities. Such obligations may e.g. follow from the Danish Companies Act, or the Money Laundering and the Financing of Terrorism (Prevention) Act.

  1. Social media platforms

Initiator uses LinkedIn as a platform to come into contact with existing and potential financers, innovators, shareholders, and other business partners, as well as to market and inform about our business. In connection with this, Initiator is the data controller for publications and information on the social media platforms that contain Personal Data and are provided by you as a user in the form of e.g. comments, photos and video. We ask our users to report unfit content to us in order for us to be able to ensure that no such content occurs on our platforms. Initiator may also, based on what we deem necessary, remove such content.

  1. Cookies

We use cookies on our Website. More information on how we use cookies can be found in our Cookie Policy at our Website.

  1. How long is your Personal Data stored?

Your Personal Data is stored only as long as needed in order to fulfil the purposes for which the Personal Data was collected in accordance with this Privacy Policy. We therefore only Process your Personal Data as long as we have a business relationship with you or the company or organization you work for or on behalf of. We consider a business relationship to have ended when we have not had any interaction with you for a full calendar year, and we will delete or anonymize data about you during the first quarter of the following year, unless we need to retain the data for other purposes as explained below.

If you have given your consent to the Processing of your Personal Data for publishing or marketing purposes, even after the business relationship has ended, Initiator Processes your Personal Data for the specific purpose, until you withdraw your consent. You can withdraw your consent at any time by (i) contacting us, or (ii) following the link in the mailings. For documentation purposes, we will retain you consent and your withdrawal of the consent for 2 years from the end of the year, where you withdraw the consent.

In order to ensure Initiator’s compliance with the legal obligations stemming from applicable legislation or in order to safeguard our legal interests we may store your Personal Data for a longer period of time. The Personal Data is however never stored for longer than is necessary or statutory for each purpose respectively.

  1. Your rights

You have a right to receive information regarding the Processing of your Personal Data we carry out. Below you find a statement of the rights you can claim by contacting us. Our contact information can be found at the very end of this Privacy Policy.

Right to access

You have a right to, free of charge, request information regarding our Processing of your Personal Data. You also have a right to receive a copy of your Personal Data that we Process. Such a request shall be submitted to us in writing with a specification of which information you wish to receive. We will respond to your request without unnecessary delay. If we cannot grant you access to the information your request concerns, we will provide a reason as to why. The copy of your Personal Data will be sent to your registered address unless otherwise is agreed with you in writing. In order to ensure your identity upon a request, we may come to request more information from you.

Right to rectification

The main responsibility to ensure that the Personal Data we Process is correct lies with Initiator as the data controller. If you inform us that the Personal Data you have provided to us is no longer correct, we will promptly correct, block or erase such Personal Data.

Right to erasure

You have the right to request that Initiator, without unnecessary delay, erases your Personal Data. Personal Data shall be erased in the following cases:

  • if the Personal Data is no longer necessary for the purposes for which it was collected;
  • if you withdraw your consent and the Processing was based solely on consent as the legal ground;
  • if Processing is carried out for purposes of direct marketing and you oppose your Personal Data being used for such purposes;
  • if you oppose the Processing of Personal Data after a balancing of interests has been carried out and your interest outweighs ours;
  • if your Personal Data has not been Processed in accordance with the Data Protection Rules; or
  • if erasure is necessary in order to comply with a legal obligation.

There may be obligations which hinder us from immediately erasing all your Personal Data. These obligations stem from applicable legislation regarding inter alia accounting. If certain Personal Data cannot be erased due to applicable legislation we will inform you of this as well as ensure that the Personal Data will be used solely for the purpose of complying with such legal obligations and not for any other purposes.

Right to restriction

You have a right to request that Initiator temporarily restricts the Processing of your Personal Data. Such a restriction can be requested in the following cases:

  • if you consider the Personal Data we have about you to be incorrect and in connection with this have requested rectification;
  • when the Processing of your Personal Data which is carried out is not compliant with the Data Protection Rules, but you still do not want your Personal Data to be erased but rather restricted; and
  • when we no longer need your Personal Data for the purposes of our Processing but you need it in order to establish, exert, or defend a legal claim.
  • If you have objected against the Processing of your Personal Data the use of your Personal Data may be restricted during the time of the investigation. Upon the restriction of your Personal Data, Initiator will only store your Personal Data and for further Processing obtain your consent.

Right to data portability

You have a right to, in the cases where we Process your Personal Data with your consent or in order to fulfil contractual obligations toward you, require that we provide you with all Personal Data we have about you and which is Processed in an automated manner, in a machine-readable format, which may be inter alia an Excel-file or a CSV-file. If it is technically possible, you further have the right to require that we transfer your Personal Data to another data controller.

Right to object

You have a right to object to our Processing of your Personal Data if the Processing is based on our legitimate interest. Initiator will in such a case ask you to specify which Processing you object to. If you object to any Processing we will only continue our Processing of the Personal Data if there are legitimate interests for Processing which outweigh your interests.

  1. Consent to the Processing of Personal Data

If we request your consent for processing your personal data for specific purposes,  it is fully op to you to decide, if you wish to consent to the intend Processing as well as if and when you wish to withdraw your consent. You can withdraw your consent by (i) contacting us, or (ii) following the link in the mailings. We will of course not make your personal data subject to any processing activity requiring your consent, unless you have provided a valid consent, and we will cease such processing without undue delay after becoming aware that you wish to withdraw your consent. Withdrawal of consent will only have future effect and will not affect the lawfulness of processing activities carried out prior to your withdrawal of the consent.

  1. To whom do we transfer your Personal Data?

In order to provide some of our services we appoint select third parties. This entails that we share some of the Personal Data we have collected with them, e.g. to Initiator’s project companies and other business partners which provide services for Initiator. In connection with such transfer of your Personal Data, Initiator takes organisational and technical measures in order to ensure that your Personal Data is handled as safe and secure as possible. These selected third parties will only process your Personal Data in manners which follow from this Privacy Policy and in order to fulfil one or more of the purposes which are listed in this Privacy Policy. Initiator is responsible toward you for ensuring that the Processing of your Personal Data carried out by these third parties is carried out in a correct and legal manner.

We will disclose your Personal Data if it is required by law or if we, as a company, reasonably deem it to be necessary in order to protect our rights and/or in order to comply with a court ruling or abide by the verdict of a legal negotiation or legal process. We will however do everything we can to ensure that your Personal Data will remain protected in the future.

As the business is conducted today, Initiator will not sell your Personal Data to a third party unless we have previously obtained your consent. However, we may, in the case that Initiator decides to sell, buy, merge with another company or organization, or in any other way reorganize the business, transfer your Personal Data to potential or actual buyers and their potential advisors.

  1. How do we protect your Personal Data?

In order to protect your personal integrity, discover, prevent and limit the risks of a hacking attack etc., Initiator takes several technical and organizational information safety measures. Initiator also takes measures in order to protect your Personal Information against unauthorised access, misuse, reveals, changes and damages. Initiator ensures that access to your Personal Information is only granted to employees who need to Process it in order to fulfil their work assignments, and that they abide by confidentiality in accordance with Initiator’s applicable policies and routines.

  1. Supervision and compliance

If you are dissatisfied with how your Personal Data has been Processed or believe that your Personal Data has been Processed contrary to the Data Protection Rules you can at first-hand contact [email protected]. You can also file a complaint to the supervisory authority, which currently is Datatilsynet/Danish Data Protection Agency. More information on how to file a complaint can be found at www.datatilsynet.dk.

Initiator annually reviews this Privacy Policy.

  1. Changes to the Privacy Policy

Initiator reserves the right to change this Privacy Policy when we deem it to be necessary in order to comply with applicable legislation. Such changes are especially warranted upon potential changes in legislation, due to statements from the supervisory authority or other authorities issuing statements pertaining to the Data Protection Rules. Further, this Privacy Policy will be updated when it is necessary due to changes in our business activities.

If Initiator makes comprehensive changes to this Privacy Policy or changes concerning how we Process your Personal Data, you will be informed of this before such a change come in to force.

  1. How do you contact us?

If you have questions pertaining to this Privacy Policy or the current Processing of your Personal Data, wish to file a request in accordance with this Privacy Policy or wish to report a violation of this Privacy Policy etc., you are welcome to contact us on the following:

INITIATOR PHARMA A/S

Corporate Identity Number 3766 3808

Ole Maaloes vej 3
DK-2200 Copenhagen
Denmark

E-mail: [email protected]

Phone number: +45-61 26 00 35

This Privacy Policy was published 2021-10-24