Privacy Policy
Our Policy:
Welcome to SurfaceOncology.com. This website (the “Site”, ) is operated by Surface Oncology, Inc. and our Privacy Policy has been created to provide information about our practices and policies with regard to the collection, use, transfer and security of data collected from our Site visitors. As used in this Privacy Policy, “you,” “visitors,” and “users” refer to people who visit the Site; “Surface,” “Surface Oncology,” “we,” “us,” and “our” refer to Surface Oncology, Inc. and its affiliates. This Privacy Policy is incorporated into and is part of the Terms of Use of using our Site. By accessing the Site, you agree to be bound by this Privacy Policy.
Information We Collect:
When you interact with us through the Site, we may collect Personal Data and other Non-Identifiable Data from you, as further described below. “Personal Data” includes information about, or relating to, an identified or identifiable person, or that can be linked to a person, such as name, contact information, email address, phone number and date of birth. Some Personal Data are voluntarily provided by users, while other Personal Data are automatically collected when you visit our Site. “Non-Identifiable Data” includes information that cannot be used to identify, or be linked to, an individual.
Personal Data That You Provide
We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, information requests or apply for a job at Surface, respond to one of our surveys, or register to receive email alerts from Surface (collectively, “Company Services”). Wherever Surface collects Personal Data, we make an effort to provide a link to this Privacy Policy. By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to this Site, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Surface and the authorized third parties referred to herein located in the United States.
Personal Data That Are Automatically Collected
Certain Personal Data may be automatically collected when you use the Site. Such Personal Data is limited to technical information and information about your visit to the Site, including pages you visited, the order in which they were visited, page interaction information (such as the links you “clicked” or the content you viewed or consumed), the type of device you are using, IP address, operating system, header information and browser software. We may collect information that allows us to associate you with your social media or other accounts that you have on other websites. Further we may collect Personal Data through the use of cookies (see “Cookies” below). Where such automatically collected information meets the definition of Personal Data, such as IP address, we will treat it as such.
Non-Identifiable Data
When you interact with Surface Oncology through the Site, we receive and store certain Non-Identifiable Data. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Surface Oncology may store such information itself or such information may be included in databases owned and maintained by Surface Oncology affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.
Cookies
A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Site without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site’s features.
Use of Personal Data and Non-Identifiable Data:
Surface Oncology related companies may also use your Personal Data and Non-Identifiable Data collected through the Site to help us improve the content and functionality of the Site, to better understand our users, to process your job application and to contact you and to improve the Company Services. Surface Oncology and its affiliates may use this information to contact you in the future to respond to your comments and questions and tell you about Company Services we believe may be of interest to you. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
Our Disclosure of Your Personal Data and Non-Identifiable Data:
Surface Oncology is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
Business Transfers
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Third Party Service Providers
We may share your Personal Data with third party service providers, including cloud and employee recruitment/hiring service providers, to help us with our business activities such as Site maintenance and employee recruitment. We include provisions within our contracts with these businesses to ensure that they: (i) use your Personal Data only as necessary to provide these services to us; and (ii) establish safeguards to protect the confidentiality of the information that we provide them.
Legal Requirements
Surface Oncology may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Surface Oncology, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
Your Choices:
You can use the Site without providing any Personal Data. If you choose not to provide any Personal Data, you can still access the Site, but your experience may be different and certain functions might not be available.
Children:
Surface Oncology does not knowingly collect Personal Data from children under the age of 15; similarly, the Site is not intended to be used or accessed by anyone younger than the age of 15. If you are under the age of 15, please do not submit any Personal Data through the Site. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on this Site without their permission. If you have reason to believe that a child under the age of 15 has provided Personal Data to Surface Oncology through this Site, please contact us, and we will endeavor to delete that information from our databases.
Special Notices for European Union Users:
For European users, this Privacy Policy only applies to Personal Data collected via the Site. If you have provided Personal Data to Surface through some other means besides the Site, such as in connection with a clinical study sponsored by Surface in Europe, you will have received a separate notice concerning your Personal Data. Please refer to that notice first if you have any concerns about our processing of your Personal Data, as that notice will contain important information and a designated contact person for concerns – but you can always contact us should you have questions or require any additional information.
| Name of Data Controller and Contact Information | Surface Oncology, Inc. 50 Hampshire Street, 8th Floor Cambridge, MA 02139 Email: PrivacyLead@surfaceoncology.com |
| Purposes of the Processing | The purposes of the processing are described in the Information We Collect and Use of Personal Data and Non-Identifiable Data sections of this Privacy Policy. |
| Lawful Basis for the Processing | Generally, we process Personal Data on the basis that the processing is necessary for purposes of our legitimate interest in conducting our business in a manner typical in the US pharmaceutical industry, having taken into account any risks to your fundamental rights and freedoms (including your right to privacy). We also may process personal data on other bases permitted by the European Union’s General Data Protection Regulation (“GDPR”) and other applicable laws, such as when the processing is necessary for us to comply with our legal obligations. |
| The Legitimate Interests of the Controller or Third Party, where applicable | Our specific legitimate interests, such as improving the Site, providing you with support, and processing and responding to any employment application, are described in the Information We Collect and Use of Personal Data and Non-Identifiable Data sections of this Privacy Policy. |
| The Categories of Personal Data Concerned | The categories of Personal Data that we process are described in Information We Collect and Disclosure of Personal Data and Non-Identifiable Data sections of this Privacy Policy. |
| The Recipients or Categories of Recipients of the Personal Data | The potential recipients of the Personal Data that we collect via the Website are described in the Information We Collect and Use of Personal Data and Non-Identifiable Data sections of this Privacy Policy. |
| Information Regarding Transfers of Personal Data Outside of the European Economic Area (EEA) and the United Kingdom (UK) | Surface Oncology, Inc. is headquartered in the USA and the Site is hosted in the USA. Surface Oncology is not established in the EEA/UK.
When you provide your Personal Data to us via the Site, you are providing your Personal Data directly to the USA. When you contact us by email, you are directly providing your Personal Data directly to the USA. Before you provide your Personal Data to us via the Site, we request your explicit consent to the transfer of your Personal Data to the USA. When you email us, the fact that you have chosen to email us knowing that we are located in the USA will be understood to constitute your express consent to the transfer of the Personal Data in your email (including your email address) to the USA. Personal Data submitted through the Life Under the Surface portion of the Site is transferred to a third party applicant tracking service provider committed to compliance with GDPR and the E.U.-U.S. Privacy Shield Framework. We safeguard your Personal Data as described in this Privacy Policy irrespective of our obligations under U.S. law. If we transfer your Personal Data to a third party, we require the third party to commit contractually to process your Personal Data only in ways that are consistent with this Privacy Policy. |
| The Period for Which the Personal Data Will Be stored, or the Criteria for Determining the Retention Period | How long we retain Personal Data varies according to the type of data in question and the purpose for which it is used. We delete Personal Data within a reasonable period after we no longer need to use it for the purpose for which it was collected or for any subsequent purpose that is compatible with the original purpose. This does not affect your right to request that we delete your Personal Data before the end of its retention period. We may archive Personal Data (which means storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures. |
| Your Rights to Access, Correct, Restrict or Delete Your Personal Data and Object to Processing | You have the right to request access to your Personal Data, to have your Personal Data corrected, restricted or deleted, and to object to our processing of your Personal Data. Your rights may be subject to various limitations under the GDPR. If you wish to exercise any of these rights, or if you have any concerns about our processing of your Personal Data, please contact us in any of the ways listed in the section “Contact Us”. The GDPR’s data portability rights are not relevant to the kinds of processing that we do. |
| The Right to Lodge a Complaint with a Supervisory Authority | You have the right to file a complaint concerning our processing of your Personal Data with your national (or in some countries, regional) data protection authority. The EU Commission has a list here. |
| Statutory or Contractual Requirement or Other Obligation to Provide Any Personal Data | Users of the Site are under no statutory or contractual requirement or other obligation to provide Personal Data to Surface via the Site. |
Security:
Surface Oncology takes reasonable steps to protect the Personal Data provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no internet or email transmission is ever fully secure or error free. In particular, email sent to or from this Site may not be secure. Therefore, you should take special care in deciding what information you send to us. Please keep this in mind when disclosing any Personal Data to Surface Oncology via the internet.
Links to Other Websites:
This Privacy Policy applies only to the Site. This Site may contain links to other websites not operated or controlled by Surface Oncology (the “Third-Party Sites”). The policies and procedures we described here do not apply to the Third-Party Sites or to any collection of your Personal Data after you click on links to such Third-Party Sites. The links from this Site do not imply that Surface Oncology endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.
Other Terms and Conditions:
Your access to and use of this Site is subject to our Terms of Use.
Changes to Surface Oncology’s Privacy Policy:
The Site and our business may change from time to time. As a result, at times it may be necessary for Surface Oncology to make changes to this Privacy Policy. Surface Oncology reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. Your continued use of the Site after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
Access to Information; Contacting Surface Oncology:
All users may review, update, correct or delete their Personal Data where the right to do so is provided by applicable law by contacting us as specified below. We will take reasonable steps to honor your request with respect to your Personal Data in our possession and will comply with applicable laws relating to your request. We may retain an archived copy of your records as required by law or for legitimate business purposes. Please also feel free to contact us if you have any questions about Surface Oncology’s Privacy Policy or the information practices of this Site.
You may contact us with queries regarding your Personal Data as follows: PrivacyLead@surfaceoncology.com.