Effective date: February 10, 2022
This Privacy Notice explains how T-knife Therapeutics, Inc., a Delaware corporation, located at 180 Sansome Street, Suite 1000, San Francisco, CA 94104 and Affiliate/wholly owned subsidiary T-knife GmbH, Robert-Roessle-Str. 10, 13125 Berlin 60064 (“T-knife”) may collect, use and process Personal Data about you through your online and off-line interactions with us (including via its websites) or where T-Knife may receive your Personal Data from a third party (collectively, “T-knife Alliances”). This policy is intended to inform you about your rights according to the European General Data Protection Regulation (“GDPR“) and the California Consumer Privacy Act (“CCPA”). The legal entity responsible for processing your data (“controller”) is T-knife Therapeutics, Inc. (for more information, please click here).
Personal Data We May Collect
We do not identify visitors to our website unless you are asked and you elect to register for a T-knife program or offer. However, when you visit our website, we will collect the following data which the browser transmits to our server and the server stores temporarily (for 90 days):
- The IP address of your computer
- Date and time of access
- Name and address of the called file
- Amount of data transmitted
- Message whether the retrieval was successful
- Identification data of the browser and operating system used
- The name of your internet service provider
Use of this data is necessary so you can, to the extent required, register with our site and avail yourself of our programs in addition to optimizing Your use of the website. In addition, we may analyze, anonymize, and/or aggregate the data in such a way as not to identify You or any individual users. T-knife uses this information for statistical purposes, and to ensure system security, technical administration of the network infrastructure, and to improve your online experience.
Personal Data we collect from you or from other sources
T-Knife may collect personal data as bulleted below (“Personal Data”) as a part of a registration or consenting process, or to communicate with you in response to inquiries. T-knife may also obtain Personal Data indirectly, such as from publicly available sources (e.g., websites or publicly accessible databases), third-party data vendors, health care providers and health insurance companies, and third-party partners and collaborators. We may combine Personal Data from multiple online and off-line sources. The categories of Personal Data that T-knife may collect about you include:
- Direct identifiers and contact information, including your name, address, phone number, or email address
- Registration information, such as your username and password
- Relationship data, including information about products, treatments and health conditions that are of interest to you
- Transaction data, including purchases and inquiries
- Financial account data, such as your credit card number
- Income and demographic information, such as when you request financial assistance for one of our products
- Health-related information, such as information about a health condition, safety and health information in relation to any of our products, or insurance and demographic information
- Payment-related information if you provide a service to T-knife
How we may use Personal Data
We may use your Personal Data for the business and commercial purposes, for communicating with you, for improving T-knife services or offerings, and for other internal business purposes.
Administering programs, services, and other interactions with you
We may use your Personal Data for everyday business purposes, such as website administration, corporate governance, and reporting obligations. We may also use your Personal Data to provide you with the programs or services that you requested, or to administer T-knife clinical programs and other services. We may also use your Personal Data to respond to your questions, provide you with your requested information, offer you an optimal customer experience, perform our contractual obligations to you, or perform actions based on your consent.
Marketing communications and disease awareness
We provide marketing communications that promote the use of or offer participation in T-knife products, services, programs, research, clinical trials, or other events or to provide other information that may be of interest to you, such as information on certain health conditions. We will use your Personal Data to send you marketing communications and to determine the types of marketing communications to send. You can always opt-out of marketing communications at any time. Marketing communication opt-out instructions are included in each marketing communication you receive, or you can email us ComplianceOfficer@T-knife.com.
Customized experiences and improving Alliances
Personal Data may be used to create customized offers, information, or services tailored to your interests and preferences. In some cases, we collect your Personal Data with your consent. In other cases, we collect this information for our legitimate business interest to optimize and customize T-knife programs.
Business and product administration and improvement
In order to discover new facts that could help T-knife better understand customer needs and help improve, develop, and evaluate programs and treatments, T-knife analyzes Personal Data for its legitimate interests in business and product development and improvement.
Compliance with laws and regulations
We may process your Personal Data to comply with laws and regulations, including those related to pharmacovigilance. We may also use Personal Data to monitor compliance with our policies and procedures, for fraud prevention, and to investigate and prosecute users who violate our rules or who engage in behavior that is illegal or harmful to others or to others’ property.
How we may disclose Personal Data
We generally share Personal Data with third parties for the business and commercial purposes described below, including third parties we use for recruiting, website analytics, reporting, public relations and marketing. We do not and will not sell your Personal Data to third parties.
Affiliates and vendors
We have Alliances with various vendors, including our affiliated companies, that help us operate our business and for whom it may be required to have access to your Personal Data in the course of providing services to T-knife. We require them to handle your Personal Data collected through the T-knife Alliances in accordance with appropriate contractual privacy and security provisions.
Business and research partners
We may partner with other companies and public and private organizations to provide you with products, content, or services. You should be aware that, in such cases, in addition to this Privacy Notice, the relevant partner’s privacy notice may also apply, for example, on T-knife’s profile contained in LinkedIn (LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA). Only when the link is clicked, the provider (such as LinkedIn) receives information (including personal data if applicable) about your visit. For more information, please refer to: LinkedIn-privacy-policy or consult other relevant privacy policies for any third parties you may encounter, including those connected with our recruitment efforts, found here: Plus, Indeed, ZipRecruiter and JobVector. In addition, we may disclose Personal Data to our external auditors, attorneys, accountants, and similar professionals based on our legitimate interest in the operation of our business and our obligations to comply with applicable laws and regulations.
Disclosures for legal obligations, to authorities and for product safety
If you contact T-knife regarding your experience using our products, we may use the information you provide to us to submit our reports to the U.S. Food and Drug Administration, other similar health and medicine government agencies outside of the United States, as may otherwise be required of us by law. We also may use the information to contact your prescribing physician (or other healthcare providers associated with a clinical trial in which you may be participating) to follow up regarding an unexpected event involving the use of our product.
In certain limited circumstances, we may need to disclose your Personal Data to comply with a legal obligation, process, or demand and for reasons of public interest, such as to comply with reporting obligations to our governing regulatory authorities regarding the safety of our products, in response to a subpoena, or to meet national security or law enforcement requirements.
Disclosure to subsequent owner or operator
We may transfer your Personal Data to a successor entity upon a merger, consolidation or other corporate reorganization, to a purchaser of all or a portion of our assets, or pursuant to a financing arrangement or co-promotional agreement. The Personal Data we have about you may be transferred to parties to the transaction based on our legitimate interest in preparing for and completing the transaction. Any successor entity shall be bound by terms and conditions reasonably similar to this Privacy Notice.
Additional information for online interactions and cookies privacy statement
Personal Data that may be collected automatically through our websites and mobile applications
We may collect the following additional categories of Personal Data through your usage of our websites and mobile applications.
We may record the Internet Protocol (“IP”) address of your computer or other electronic device when you visit our website. An IP address identifies the electronic device you use to access websites, which allows us to maintain communication with your device and to customize content.
Cookies and other data-collection technologies
We collect information automatically through your online interactions with us through tracking and data-collection technologies such as cookies, web beacons and pixels, APIs, web services, scripts, browser analysis tools, and server logs. A “cookie” is a unique numeric code that is transferred to your computer to track your interests and preferences and to recognize you as a return visitor. A “Web beacon” (also known as a pixel tag) is a transparent graphic image placed on a website, email, or advertisement that enables the monitoring of things such as user activity and site traffic, including the collection of data about the website and mobile application you were visiting before and after you came to our website or mobile application. To learn more about cookies and other data-collection technologies, please visit all about cookies.
We classify our cookies into the following categories:
- Required Cookies: These cookies are necessary for core features of a site to operate properly. These are always active.
- Functional Cookies: These cookies allow us to analyze site usage to evaluate and improve its performance. They are also used to provide a better user experience on the site, such as measuring interactions with particular content or remembering settings. These are always active.
- Advertising Cookies: These cookies are used to show you ads that are more relevant to you. We may share this information with advertisers or use it to better understand your interests. For example, advertising cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.
You can disable cookies through your browser. Please note that some cookies are essential to the functioning of our websites and deleting or disabling them on your browser will reduce the site’s functionality.
How we may use Personal Data through online interactions
In addition to the uses described separately in this Privacy Notice, we may use your Personal Data collected online for the additional purposes as described in this section.
Customized user experiences
In some cases, we collect this Personal Data with your consent. In other cases, we collect this information for our legitimate business interest to optimize and customize your user experience.
As for Consent. Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6(1)(a) of the GDPR serves as the legal basis.
As for legitimate business interests:
In the processing of personal data required for the performance of a contract of which the data subject is a contracting party, Art. 6(1)(b) GDPR serves as the legal basis for such processing. This also applies to processing operations that are necessary to carry out pre-contractual measures.
Insofar as the processing of personal data is required to fulfill a legal obligation to which the T-Knife Alliances is subject, Art. 6(1)(d) GDPR serves as the legal basis for such processing.
In case that vital interests of the concerned person or another natural person necessitate the processing of personal data, Art. 6(1)(f) of the GDPR serves as the legal basis for such processing.
If the processing is required for safeguarding the legitimate interest of T-Knife Alliances, or that of a third party, and if the interests, fundamental rights and freedoms of the data subject do not outweigh the such interest, Art. 6(1)(f) of the GDPR serves as the legal basis for such processing.
Digital analytics and improvement
We may use the Personal Data that you provide to us and the online information we collect automatically through cookies and similar tracking technologies to monitor user traffic patterns and preferences. We may also track email communications through web beacons or similar tracking technology in emails to create aggregated statistics and reports to analyze the effectiveness of and improve our marketing campaigns. We collect this information for our legitimate business interests of security, improvement, analytics, and optimization of T-knife Alliances.
Social Media Analysis
Data security and retention
T-Knife maintains appropriate technical, administrative, and physical controls to reasonably safeguard any Personal Data collected through T-Knife Alliances. However, there is always some risk that an unauthorized third party could intercept an internet transmission, or that someone will find a way to thwart our security systems. We urge you to exercise caution when transmitting Personal Data over the internet, especially your health-related information. We cannot guarantee that unauthorized third parties will not gain access to Personal Data about you; therefore, when submitting Personal Data to us, you must weigh both the benefits and the risks.
We will only keep Personal Data if necessary for the fulfillment of the purposes outlined in this Privacy Notice, except if otherwise required by applicable laws or legal orders. The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal or best practice retention obligation to which we are subject; and (iii) whether retention is needed considering litigation or regulatory investigations.
How your Personal Data may be shared through online interactions
In addition to the types of disclosures of Personal Data described separately in this Privacy Notice, we may share Personal Data online for the additional purposes as described in this section.
Third-party advertising and online behavioral advertising
We may provide you with online advertisements for T-knife products and services on third-party websites and mobile services that are tailored to you, which may be based on the Personal Data that you provide to us or to a third-party website that you are visiting, or on your browsing activity, purchases, or interests. We may share some of your device information with our advertising service providers that we have obtained from cookies and other data-collection and tracking technologies based on your T-knife Alliances.
You can disable cookies through your browser.
Links to third-party sites and social media plug-ins
This Privacy Notice only applies to T-knife Alliances linked to this Privacy Notice and does not apply to third-party websites to which T-knife Alliances may link, including links to outside websites or advertisements from third parties. We encourage you to review the privacy statements provided by all third parties prior to providing them with Personal Data.
Additional information for California residents
If you are a California resident, you have certain rights with respect to T-knife’s use and disclosure of your Personal Data. Those California-specific privacy requirements not addressed in other Privacy Notice sections are described here.
Consistent with the collection practices described in this Privacy Notice, we may collect certain categories and specific pieces of Personal Data either from your or from other third parties. We collect, use, and disclose Personal Data for our business and commercial purposes described in this Privacy Notice. T-knife does not sell Personal Data. Furthermore, T-knife receives, and may further share with its collaborators and partners, deidentified health data from health care providers and health plans, subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). The health data received by T-knife was deidentified based on either HIPAA’s “safe harbor” method, which means that certain direct identifiers were removed from the health data, or HIPAA’s expert determination method, which means that a qualified statistician or expert with industry experience has reviewed the health data shared with T-knife and confirmed that there is a very small risk that an individual could be identified from the remaining health data.
As a California resident, you have the right to request:
- Information about the Personal Data that T-knife has collected, used, and disclosed about you over the previous 12 months. This includes:
- the categories of Personal Data collected
- the categories of sources from which your Personal Data was collected
- the business or commercial purposes for which T-knife collected your Personal Data
- the categories of your Personal Data that was disclosed for a business or commercial purpose
- the categories of third parties with whom T-knife shared your Personal Data
- The specific Personal Data that T-knife has collected about you over the previous 12 month.
- To have your Personal Data deleted
Should you exercise any of your privacy rights as a California resident, T-knife will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products or services, based solely upon this request. However, certain T-knife Alliances may require your consent to have your Personal Data shared with T-knife to provide the service or to allow us to use and disclose your Personal Data to provide the T-knife Alliances. When you exercise your deletion right, you may lose access to certain aspects of T-knife Alliances that require your Personal Data to perform the service.
Additional information for job applicants
If you have applied for employment with T-knife, the Personal Data submitted with your job application may include your resume; previous professional, education and other background information; driver’s license information; social security number or equivalent national identification (as required or permitted by local law); cover letter; licenses; permits and certifications held; reference information; and any other information that you choose to provide (e.g., employment preferences, willingness to relocate, awards or professional memberships). This information may come from you, a recruiter, your references, prior employers, or your educational institutions.
Consistent with applicable law, we may ask questions about race/ethnic origin, gender, veteran status, and disability status of our applicants, for the monitoring of equal employment opportunity compliance. Except as specifically requested or legally required, we ask that you avoid submitting information in your application that may qualify as sensitive information under applicable law. Sensitive information includes data about race, color, religion, ethnicity, nationality or national origin, age, gender identity or expression, sexual orientation, marital status, medical or health information (including physical or mental disabilities or pregnancy status), genetic or biometric information, political or philosophical beliefs, political party or trade union membership, veteran status, photographs, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings, or any other legally protected status.
Personal Data will be processed based on our legitimate interest in processing your job application and evaluating your candidacy and qualifications and to conduct reference checks. We may also inquire about criminal records and perform a background check following a conditional offer of employment, where permitted by applicable law. We may also process Personal Data from your job application for regulatory, compliance and legal purposes, consistent with this Privacy Notice. Personal Data may be also be used for additional administrative purposes, including aggregate management reporting, internal training, and as generally required to operate our business.
We may share the data on your applications with recruiters, consultants, attorneys, preemployment background check services, and our affiliates. We may keep the data for a period of time prescribed by local applicable law or for such period that we have your consent to retain the same.
Additional information for health care professionals
We may collect additional categories of Personal Data if you are a health care professional, as described in this section. We also use and disclose Personal Data about health care professionals for the additional purposes described in this section. The categories of Personal Data collected and the purposes of use and disclosure described in this section are in addition any other collection, use and disclosure of Personal Data practices described separately in this Privacy Notice.
Additional Personal Data that T-Knife may collect about health care professionals
If you are health care professional, we may collect Personal Data about you directly from you, or from third-party sources such as the organization where you work, publicly available sources, interactions with T-knife (including online available sources), and participation in T-knife-sponsored or -supported initiatives such as T-knife-sponsored clinical research and development activities, third-party databases, and reporters of pharmacovigilance events.
We may collect the following additional categories of Personal Data about health care professionals:
- Professional details, such as resumes or other documents or forms provided directly to us, place of practice, job title, professional contact details, medical specialty, professional license number, professional qualifications and scientific activities (such as previous clinical trial experience, activity on social media platforms or other websites, and participation in past or pending research studies with us and other companies), organizational or institutional affiliations, publication of academic or scientific research and articles, and membership in associations and boards.
- Personal Data provided to participate in our sponsored or -supported initiatives, such as our sponsored clinical research and development activities, online or in-person seminars regarding product information, educational events, and clinical information updates.
- Details of interactions with us, such as what kind of meetings we have held, topics discussed, your knowledge of and questions you have had about our business and products, what kind of material we have displayed to you, and any feedback that you have provided, as well as your opinions of and routines for prescribing, routines regarding your patients, diagnoses, and automatic tracking information in online interactions with us.
- Payment and other transfers of value details received from your interactions with T-knife, which may include your tax identification number or national identification number (where required or permitted by law), contributions to costs of educational events (such as registrations fees, travel and accommodation expenses) and fees for services, including consultancy services
- Based on our legal obligations and for reasons of public interest, we will use and disclose Personal Data about health care professionals for (a) safety monitoring, reporting and auditing and responding to inquiries or issues in relation to our products; (b) complying with applicable laws and regulations, including requirements imposed by industry codes of conduct to collect payment and other transfer of value data of health care professionals and the public disclosure of such data, subject to applicable local consent requirements to publish such data in a manner that identifies the health care professional individually
Additional uses of data in the context of clinical trials
With your consent, if applicable, we may use and disclose your Personal Data for clinical trial purposes, for drug safety, adverse event reporting, and/or to provide health care professional with information about your participation in a T-knife clinical program. Based on our legal obligations and for reasons of public interest, we may use and disclose your Personal Data in our programs for safety monitoring, reporting and auditing, and responding to inquiries or issues in relation to our products, as well as to comply with applicable laws and regulations. We will also use Personal Data that does not directly identify you for the purpose of analytics, research and related publication, including to evaluate, develop and improve T-knife's programs and related services.
Privacy of children
T-knife does not knowingly collect any Personal Data directly from anyone under the age of 16. All T-knife Alliances that support children are directed to and are communicated with parents and guardians only. If you are a parent or guardian and become aware that your child has provided us with Personal Data, please contact us at ComplianceOfficer@T-knife.com.
Our contact information
You may also contact us by emailing our Data Protection Officer at ComplianceOfficer@T-knife.com, if you have questions about this Privacy Notice or have any other privacy request or inquiry.
In all communications to us, please include the email address used for registration (if applicable), the website address, mobile application, or the specific program to which you provided Personal Data.
Your privacy rights and choices
Under applicable data protection law, you may have the right to request access to and/or rectify, block, or delete Personal Data relating to you, transmit Personal Data to another controller, withdraw your consent at any time (this will not affect the lawfulness of previous data-processing activities), or object to any use of your Personal Data. If we are not able to provide the requested information or make the change you requested, you will be provided with the reasons for such decisions. Under local law, you may be entitled to lodge a complaint with your local data-protection authority.
You may have the right to object to the processing activities described in this Privacy Notice that are based on our legitimate interests.
Please submit your privacy requests or inquiries to our Data Protection Officer, using the contact information ComplianceOfficer@T-knife.com.
Additional information for EU residents
Your rights to the processing of your data
information: The subject has the right to ask the person responsible for confirmation of the processing of personal data concerning him or her; if this is the case, it has a right to information about these personal data and to the information listed in Article 15 GDPR.
Right to correction: The data subject has the right to demand from the person responsible without delay the correction of inaccurate personal data concerning them and, if necessary, the completion of incomplete personal data (Art. 16 GDPR).
Right to cancellation: The data subject has the right to demand from the person responsible that personal data relating to him / her be deleted without delay, provided that one of the reasons listed in detail in Art. 17 GDPR applies, e.g. For example, if the data is no longer needed for the purposes pursued (right to delete).
Right to restriction of processing: The data subject has the right to require the person responsible to restrict the processing if one of the conditions listed in Art. 18 GDPR is fulfilled, e.g. For example, if the data subject has objected to processing for the duration of the review by the controller.
Notification obligation: The data subject has the right to be informed about the recipients of personal data. The controller shall notify all recipients of any correction or erasure of personal data or a restriction on processing under Articles 16, 17 (1) and 18, unless that proves impossible or disproportionate. (Art. 19 GDPR)
Right to data portability: The data subject has the right to receive the personal data concerning him or her provided to a responsible person in a structured, common and machine-readable format. It also has the right, if technically feasible, to obtain the transfer of this data to another person responsible (Art. 20 GDPR).
Right to object: The data subject has the right, at any time, to object to the processing of personal data for reasons arising from his or her particular situation. The controller then no longer processes the personal data unless he can demonstrate compelling legitimate grounds for processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves the assertion, exercise or defense of legal rights (Art 21 GDPR).
Right to complain: without prejudice to any other administrative or judicial remedy, each data subject has the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of personal data concerning them infringes the GDPR (Article 77 GDPR). The data subject may assert this right with a supervisory authority in the Member State of his or her residence, place of work or place of alleged infringement. In Berlin, the competent supervisory authority is:
Berlin Commissioner for Data Protection and Freedom of Information
10969 Berlin, Germany
Data security and retention
T-knife maintains appropriate technical, administrative, and physical controls to reasonably safeguard any Personal Data collected through T-knife Alliances. However, there is always some risk that an unauthorized third party could intercept an Internet transmission, or that someone will find a way to evade or penetrate our security systems. We urge you to exercise caution when transmitting Personal Data over the internet, especially your health-related information. We cannot guarantee that unauthorized third parties will not gain access to Personal Data about you; therefore, when submitting Personal Data to us, you must weigh both the benefits and the risks.
We will only keep Personal Data as long as necessary for the fulfillment of the purposes outlined in this Privacy Notice, except if otherwise required by applicable laws or legal orders, or as you may have consented. The criteria used to determine our retention periods include (i) the length of time we have an ongoing T-knife Relationship with you; (ii) whether there is a legal or best practice retention obligation to which we are subject; and (iii) whether retention is needed in light of litigation or regulatory investigations.
International Personal Data transfers
We may transfer Personal Data internationally as described in this section.
Personal Data may be transferred and processed by and among T-knife, Therapeutic, Inc. in the U.S., and its wholly owned subsidiary T-knife, GmbH, and its affiliates in other countries. For a full list of T-knife Inc.’s affiliates and their jurisdictions, please contact our Data Protection Officer at ComplianceOfficer@T-knife.com.
Transfers to vendors, suppliers, and business partners
Personal Data may also be transferred and processed by our vendors, suppliers, and business partners in other countries. Any international transfer of Personal Data to third parties, including outside the EEA, will be conducted in compliance with the international data-transfer restrictions and requirements that apply under data-protection laws, including, where appropriate, using EU model contracts for Personal Data transfers to data processors or data controllers.
Accessing our sites globally
This site is owned and operated by T-knife, Therapeutics, Inc. in the United States. If you are visiting this site from a country other than the United States, your communication with us will result in the transfer of Personal Data across international borders. We will only process your Personal Data with your consent, to perform a contract between you and us, to comply with legal obligations, or where we have a legitimate interest (as set forth above with reference to GDPR Art. 6). These legitimate interests include administrative activities and complying with your requests.
Cross border data transfers
Within the scope of our information sharing activities set out above, your personal data may be transferred to other countries (including countries outside the European Economic Area (“EEA”)) which may have different data protection standards than your country of residence. We have proper guarantees with the involved third parties in place (e.g. other operating the websites on our behalf) to ensure an adequate level of protection for personal data. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavor to take reasonable measures to keep up adequate level of data protection also when sharing your personal data with such countries. In the case of a transfer outside of the EEA, this transfer is safeguarded by EU Standard Contractual Clauses.
Changes to our Privacy Notice
We will use Personal Data only in the manner described in the Privacy Notice in effect when the Personal Data was collected. However, and subject to any applicable consent requirements, we reserve the right to change the terms of this Privacy Notice at any time. Any changes to this Privacy Notice will be promptly posted to this page and accompanied by a new effective date at the top of this page. We encourage you to review this Privacy Notice regularly for any changes. Any Personal Data collected upon your continued use of T-knife Alliances will be handled in accordance with the currently posted Privacy Notice.
Copyright © 2022 T-knife Therapeutics, Inc.
Unless otherwise specified, all product names appearing in this internet site are trademarks owned by or licensed to T-knife Therapeutic, Inc. and/or T-knife GmbH, their subsidiaries or affiliates. No use of any T-knife trademark, logo, trade name, or trade dress in this site may be made without the prior written authorization of T-knife Therapeutics, Inc., except to identify the product or services of the company.