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
Personal Data That Are Automatically Collected
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.
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:
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.
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.
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.
Special Notices for European Union Users:
|Name of Data Controller and Contact Information||Surface Oncology, Inc.
50 Hampshire Street, 8th Floor
Cambridge, MA 02139
|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.|
|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.
|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.|
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:
Other Terms and Conditions:
Access to Information; Contacting Surface Oncology:
You may contact us with queries regarding your Personal Data as follows: PrivacyLead@surfaceoncology.com.