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.
- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
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 when you register with us for additional information in the Astraeus clinical trial.
This website is not intended for children and we do not knowingly collect data relating to children.
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.
Mereo is made up of different legal entities and this privacy notice is issued on behalf of the Mereo Group so when we mention "Mereo", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Mereo Group responsible for processing your data. Mereo BioPharma Group plc together with Mereo BioPharma 4 Limited act as dual data controllers and are responsible for this website.
We have appointed a data protection officer 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 DPO using the details set out below.
Our full details are:
Full name of legal entities acting as dual controllers: Mereo BioPharma Group plc and Mereo BioPharma 4 Limited
Name or title of DPO: Mereo Data Protection Officer
Email address: email@example.com marked ‘For the attention of Mereo Data Protection Officer’
Postal address: 1 Cavendish Place, London W1G0QF, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 13Sep2018 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.
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, maiden name, last name, username or similar identifier, title
- Contact Data includes address, email address and telephone numbers
Clinical Data which includes:
- Age (between 18 and 75 years);
- Information necessary for assessing eligibility to participate in study (such data will include Sensitive Personal Data such as data concerning your health).
- 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 includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
- Usage Data includes information about how you use our website, products and services
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
We collect Sensitive Personal Data about you as described above which includes details about your health.
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 and you fail to provide the data requested, we may not be able to provide you with access to study.
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, Contact and Health Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply to access our clinical trial services;
- create an account with login and password on our website;
- subscribe to our newsletters or publications;
- request marketing to be sent to you; or
- give us some feedback.
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;
(b) advertising networks such as Google or Facebook based outside the EU; and
(c) search information providers such as Google based outside the EU.
- Technical Data from the following parties:
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:
Communications about general health information (such as information on certain health conditions)
Communications regarding our studies
Administering and maintaining voluntary patient engagement and support platforms
To determine your eligibility for certain products, services or programs
Responding to your requests for information, products, or services
Organizational planning and development (such as internal communications, budgets, administration and project management)
Our company compliance and facility and network security purposes
Internal investigations of possible misconduct or failure to comply with our policies and procedures
Auditing our programs and services for compliance purposes
Authenticating and verifying your identity in your interactions with us
Legal proceedings and government investigations (such as pursuant to warrants, subpoenas and court legal orders)
Tracking your interactions (online and offline) with us
Where we have legal obligations to process the personal data
Improvement and development of our products and services
Device and application diagnostics
Generally, we do not rely on consent as a legal basis for processing your personal data other than as follows:
- we require your explicit consent where you provide us with Sensitive Personal Data as described above in Section 2. When we ask you for your explicit consent we will provide you with the opportunity to consent electronically. You have the right to withdraw your explicit consent at any time by contacting us.
- we require your consent in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data, please
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or been provided services from us in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Mereo Group for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of being provided a service by us, product/service experience or other transactions.
You can decide to withdraw any consent or explicit consent you have given us at any time by contacting us at firstname.lastname@example.org marked ‘For the attention of the Data Protection Officer.
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 email@example.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
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 Ltd, OVH Ltd who provide IT and 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 applicable laws. 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
We share your personal data within the Mereo Group. This may involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We share your personal data within the Mereo Group. Some of our these and their database locations may be in countries that do not ensure an adequate level of data protection similar to the laws in the country in which you reside. Regardless, all our affiliates are required to treat your Personal Data in accordance with this Privacy Notice and our privacy and data protection policies and procedures.
We may transmit your Personal Data to our third parties with whom we contract to carry out services on our behalf to perform activities or functions related to the processing purposes regarding your Personal Data that are described above. Our third parties are contractually obligated to comply with applicable laws or regulations, including having a valid EU Personal Data cross-border transfer mechanism in place to receive the EU personal data, which can include an “adequacy” determination by the European Commission, EU-US and/or Swiss-US Privacy Shield certifications, and/or executing EU Standard Contractual Clauses with us.
For more information about our cross-border transfers of your Personal Data, please contact us.
7. Data security
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.
If you wish to exercise any of the rights set out above, please contact us.
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.
Time limit to respond
We try to respond to all legitimate requests within 28 days. Occasionally it may take us longer than 28 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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.
External Third Parties
- Service providers acting as processors based in the United Kingdom and France who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United States who provide consultancy, banking, legal, insurance and accounting services.