1. GENERAL

    1. This privacy policy (”Privacy Policy”), describes how Redwood Pharma AB (publ), registration number 556885-1280, Ringvägen 100E, SE-118 60 Stockholm, Sweden (“Redwood Pharma”), collects, uses, discloses, stores and otherwise processes personal data.
    2. We respect your right to privacy, and we are committed to comply with applicable data protection rules and to safeguard your We want to make sure that you are aware of what types of information we collect or obtain from you via the website or during your communication or interaction with us, how this information is used and how we work to protect it.
    3. This Privacy Policy describes, amongst other things, which information we collect about you, how yourpersonal data is processedand for what purposes we collect and use the personal data. This Privacy Policy also describes yourrights and how youcan contact us about the use of yourpersonal
    4. Redwood Pharma is the data controller responsible for processing yourpersonaldata in accordance withapplicable data protection legislation.
    5. Redwood Pharma has appointed a data protection officer (“DPO”). The DPO will, inter alia, be responsible for monitoring that Redwood Pharma’s processing of personal data is in accordance with applicable laws and regulations. If you have questions, or would like to contact our DPO for any other reason, please do not hesitate to send an email to DPO@redwoodpharma.com.
  2. WHAT TYPES OF PERSONAL DATA DO WE PROCESS?

    1. Personal data means all types of information which can, directly or indirectly, be used to identify a living physical person (“Personal Data”).
    2. Redwood Pharma collects and processes Personal Data in the form of your email address and your name when you sign up for our newsletter.
    3. Redwood Pharma further collects information that is necessary for us to be able to contact you in your role as a representative for an organization or company. Redwood Pharma collects and processes information about you if you represent an organization/company that is a supplier, contractor or otherwise partner of ours, as well as a potential supplier, contractor or otherwise partner of ours, as well as national or regional agency or otherwise. The information that we collect and process in such cases include contact information (such as name, address, work title, what organization/company you work for, email address and telephone number).
    4. Redwood Pharma also collects Personal Data in connection with recruiting staff members. When you contact us to apply for a job opportunity with us, we collect such Personal Data that you provide us with in connection with such application. Personal Data normally included in a job application is contact information (name, address, email address and telephone number), CV (including previous work experience and education), and occasionally picture and personal registration number.
    5. Furthermore, Redwood Pharma collects and processes Personal Data about you when you choose to participate in a study conducted by Redwood Pharma. Personal Data that Redwood Pharma collects and processes in such cases include name identifier such as initials (not your full name), age, sex and health information.
    6. Additionally, Redwood Pharma collects data about you that we need to improve, streamline, simplify and develop our websites, www.redwoodpharma.se and www.redwoodpharma.com, such as IP address, cookies or similar information.
  3. WHY DO WE PROCESS YOUR PERSONAL DATA?

    1. Redwood Pharma collects och process Personal Data relating to you for the following reasons:
      1. to send newsletters that you have requested and to respond to communications you have sent us;
      2. to contact you as a representative for a governmental or regional agency,
      3. to contact you as a representative of a supplier, contractor or otherwise partner of ours, and to, if applicable, administer the agreement between Redwood Pharma and such supplier, contractor or partner;
      4. to market ourselves and our services and invite you to events we believe might be of interest to you or the company that you represent (provided however, that you will always have the right to opt-out of any marketing messages from us);
      5. to develop and improve our services;
      6. to process job applications;
      7. to conduct clinical studies (only with your prior consent);
      8. to improve, streamline, simplify and develop our website, and
      9. to fulfil requirements by law.
  4. THE LEGAL BASES FOR PROCESSING PERSONAL DATA

    Redwood Pharma’s processing of your Personal Data is based on the legal grounds as follows.

    Legitimate interests

    1. The legitimate interest of Redwood Pharma constitutes the legal basis for processing in situations where you provide us with your contact information by handing us a business card or otherwise has expressed an interest in our products or services. The legitimate interests of Redwood Pharma in such cases are for Redwood Pharma to be able to market its products and services.
    2. Furthermore, the legitimate interest of Redwood Pharma is the legal basis for when Redwood Pharma is processing your personal data when you are a representative for a supplier, contractor or otherwise partner of ours. The legitimate interests of Redwood Pharma in such cases are Redwood Pharma’s need to contact you as a representative to administer the relationship Redwood Pharma has with the company/organization that you represent.
    3. The legitimate interest of Redwood Pharma is the legal basis for Redwood Pharma’s processing of your Personal Data in connection with your job application, in which cases the legitimate interests of Redwood Pharma are to be able to secure that its employees has sufficient education and experience.
    4. Additionally, the legitimate interest of Redwood Pharma is the legal basis for Redwood Pharma’s processing of your Personal Data in connection with Redwood Pharma sending out its newsletters. The legitimate interests of Redwood Pharma in such cases are for Redwood Pharma to be able to market itself and its services.
    5. Redwood Pharma’s processing of your personal data collected from you visiting our website is based on the legitimate interest of Redwood Pharma. The legitimate interest is that the processing is necessary for Redwood Pharma to be able to improve, streamline, simplify and develop its website in order to attract more partners as well as to increase the number of returning partners.

    Consent

    1. Redwood Pharma’s processing of your Personal Data is based on your consent where you have chosen to participate in a clinical study. You can at any time withdraw your consent to such processing by contacting us. For contact details see section 10 Redwood Pharma, its partners and subcontractors follow guidelines and associated regulations according to Guidelines for Good Clinical Practice (GCP E6/R2) and International Conference on Harmonization (ICH) Guidelines. Procedures for giving/managing consent by subjects in clinical trials, as well as the withdrawal from a trial, are well described in the guidelines. Subjects who wish to withdraw from a trial should contact their trial physician (investigator).

    Legal obligation

    1. Redwood Pharma may process your Personal Data for the purpose of complying with safety standards and other statutory requirements, based on the legal ground that this is necessary for compliance with a legal obligation to which Redwood Pharma is subject.
  5. FOR HOW LONG DO WE STORE YOUR PERSONAL DATA?

    1. Your Personal Data is stored only for as long as there is a need to keep the data in order tofulfilthe purposes for which the data was collectedin accordance withthis Privacy Policy. Storage of Personal Data related to clinical trials follow GCP and ICH guidelines.
    2. The Personal Data will be deletedif the purpose of collection and use of Personal Data has been achieved, or if you withdraw your consent (if applicable) to the processing of Personal Data by contacting us (for contact information, please see Section 10below). Personal Data received in connection with a job application for an applicant that is not hired will be stored for no longer than one year after the date of the application.
  6. HOW MAY YOUR PERSONAL DATA BE SHARED?

    1. Redwood Pharma will not sell, trade or lease your Personal Data to third parties. However, Redwood Pharma may share Personal Data with our trusted subcontractors and co-operation partners in order toprovide you with our services. They may need access to your Personal Data in their assignment forus, but they will not be allowed to use the Personal Data for any other purpose.
    2. Unless otherwise set forth below or in any specific information regarding our processing of your Personal Data, Redwood Pharma will not transfer your Personal Data to any country outside the EU/EEA.
    3. Personal Data that Redwood Pharma collect may be transferred to Internet service providers established outside of EU/EEA as a part of such Internet service provider’s provision of services to Redwood Pharma. Personal Data will also be transferred to USA through Redwood Pharma’s use of Dropbox, Office 365 (Microsoft) and Google Analytics. Redwood Pharma has ensured that your rights are guaranteed before making such transfer to USA by Microsoft’s and Google’s adherence to EU-US Privacy Shield. More information is available at www.privacyshield.gov.
    4. Personal Data may be disclosed by Redwood Pharma to comply with legal requirements or other requirementsfrom official authorities, in order tosafeguard Redwood Pharma’s legal interests or to detect, prevent, or draw attention to frauds or other safety or technical problems.
    5. Should Redwood Pharma intend to transfer all or part of its business, personal data may be disclosed to a potential buyer.
  7. PROTECTION OF YOUR PERSONAL DATA

    1. You should always feel secure when you provide your Personal Data to us. We have employed a wide range of security measures to help protect your Personal Data against undue access, modificationand deletion.
    2. We protect your Personal Data using commercially reasonable safeguards to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include data encryption, firewalls, automatic timeouts and one-time access links that expire within hours. Therefore, you can rest assure that your Personal Data is in safe hands.
  8. YOUR RIGHTS

    Access, rectification and erasure

    1. You are always entitled to obtain access to your Personal Data and receive a copy of the Personal Data being processed. Guidelines for access to clinical trial data by subjects are covered by ICH and GCP.
    2. You are also entitled to request that we correct or update any inaccurate personal data.

    Restriction of use and data portability

    1. Under certain circumstances (expressed in applicable data protection legislation),you may request that Redwood Pharma restricts the use of your Personal Data or delete your Personal Data. If you have provided us with Personal Data, you also have the right to have your Personal Data resubmitted to you, in a structured and accessible format, for transfer to another user/processor.

    Object

    1. You have the right to object to any processing based on our legitimate interests.

    Requests and Complaints

    1. If you wish to exercise any of the abovementioned rights or if you have any questions regarding Personal Data held by us or this online Privacy Policy, please do not hesitate to contact us (for contact information,please see section 10below).
    2. Should you be dissatisfied with our processing of your Personal Data, please let us know,and we will do our best to meet your complaints. Your integrity is very importantto us, and we always strive to protect and secure your Personal Data in the best possible way. Should we nevertheless, in your opinion, fail in this ambition, please note that you are also entitled to lodge a complaint with the Swedish Data Protection Authority (Sw. Datainspektionen), or such other authority as may be determined in the future.
  9. CHANGES TO THIS PRIVACY POLICY

    Redwood Pharma may, at any time, make amendments to this Privacy Policy. Redwood Pharma will publish the amended version at our website. If the amendments are substantial, Redwood Pharma will send the amended Privacy Policy to your email, and if Redwood Pharma does not have your email, Redwood Pharma will send it to you by other means (if possible).

  10. HOW TO CONTACT US

    You can contact us at: Redwood Pharma AB, Ringvägen 100E, SE-118 60 Stockholm, Sweden, or at our email:martin.vidaeus@redwoodpharma.com. Our DPO can be contacted by email on DPO@redwoodpharma.com.