Welcome to our privacy notice.

We respect your privacy and we are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format, so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

2. The data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Glossary 

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Cerevel Therapeutics, LLC is the controller and responsible for your personal data (collectively referred to as "COMPANY", ”Cerevel”, "we", "us" or "our" in this privacy notice).

Cerevel’s registered office is located at 131 Dartmouth Street, Suite 502, Boston, MA 02116, United States.

Cerevel has appointed a Data Protection Representative in the EU as required by the GDPR who is: MyData-Trust SA., based at Boulevard Initialis 7-B3, 7000 Mons, Belgium.

Cerevel undertakes to strictly comply with its obligations under all applicable laws and regulations, including, but not limited to, the European Union (EU), the European Economic Area (EEA) and their Member States, applicable to the processing of this data, including the General Data Protection Regulation EU 2016/679 (GDPR).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise Your legal rights, please contact the Cerevel Data Protection Officer at DPO@cerevel.com

You also have the right to lodge a complaint with your local Data Protection Authority or to the Data Protection Authority where the alleged infringement took place.  The EU Commission has a list of data protection authorities via the following link: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

 

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 24 September 2020 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

 

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, last name, username or similar identifier, title, qualifications, and your place of work.
• Contact Data includes address, email address and telephone numbers
• Qualifying Data includes location information
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
• Profile Data includesyour username and password, preferences, feedback and survey responses
• Usage Data includes information about how you use our website

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the contract you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact and Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Agreed to be involved as an Investigator or member of the Research Staff engaged for the clinical trial;
  • create an account with login and password on our website;
  • give us some feedback.

 

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

 

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public source as set out below:
  • Technical Data from the following parties:

(a)        analytics providers such as Google based outside the EU;

 

4. How we use your personal data

We will only use your personal data when the law allows us to. Processing of your Personal Data includes where we may adapt, align, alter, combine, consult, destroy, disclose by transmission, dissemination, erase, organize, record, restrict, retrieve, store, structure, use, or otherwise make available.

Most commonly, we will use your personal data in the following circumstances:

Providing you with access/login credentials for this website	Communications regarding our studies
Allow you to download the documents related to the clinical trial that are stored on this website	Our company compliance and facility and network security purposes
Auditing our programs and services for compliance purposes	Authenticating and verifying your identity in your interactions with us
Where we have legal obligations to process the personal data	Tracking your interactions (online and offline) with us
website administration	Statistical analysis

 

On which basis do we use your personal data

The legal basis for the processing of your personal information lies in our legitimate interest in controlling access to the portal/platform and thus guaranteeing data security.

 

Cookie Policy

When you visit the Services, some information is also automatically collected, such as your computer’s Internet Protocol (IP) address, your computer’s operating system, the browser type, the address of a referring web site, and the time and date of your visit and pages visited. This information is collected through the use of “cookies.” A cookie is a piece of information that the computer that hosts our Service gives to your browser when you access the Service. We use cookies on the Services to help optimize your online experience.

 

Cerevel does not require that you accept cookies; however, some functionality on the Services may be disabled if you decline to accept cookies. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at DPO@cerevel.com

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5. Disclosures of your personal data

This website will be accessed by parties involved in the clinical trials:

• Data controller and Sponsor of the study, Cerevel.
• Data Processors: Syneos, Study Sites and Principal Investigators and Neonstone.

We may have to share your personal data with the parties set out below:

• Internal Third Parties as set out in the Glossary
• External Third Parties as set out in the Glossary
• Specific third parties such as Neonstone Limited and OVH Limited who provide hosting services in respect of this website and related IT services.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Your personal data will be transferred in countries that do not provide the same standard of legal protection as in the EU, such as the country where the data controller is based. In these cases, either the third country recipient is recognized as having an adequate level of data protection, or appropriate safeguards will be put in place by us to ensure the protection of your personal data. You have the right to ask for a copy of these appropriate safeguards by contacting our Data Protection Officer at DPO@cerevel.com.

 

7. Data security

We appointed Neonstone as the party in charge of building and maintaining this website. Neonstone adopted guidance to ensure systems and tools are in place to prevent data corruption via malware and have backup system protections to prevent loss of data.  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

These rights are not absolute, are limited to be exercised, and they will be evaluated on a case-by-case basis.

• If you would like to exercise your rights related to this policy, then please submit a request to the Cerevel Data Protection Officer at DPO@cerevel.com
• You also have the right to lodge a complaint with your local Data Protection Authority or to the Data Protection Authority where the alleged infringement took place.

 

The EU Commission has a list of data protection authorities via the following link:

https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

 

Contacts

Cerevel Therapeutics LLC.

131 Dartmouth Street, Suite 502, Boston, MA 02116, United States

info@cerevel.com

 

 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers acting as processors based in the United Kingdom and France who provide IT and system administration services.