Privacy Policy

Privacy Policy

Roivant Sciences and its respective subsidiaries and affiliates (“Roivant Sciences”, “we”, “us”, or “our”) recognizes the importance of protecting your privacy. This Privacy Policy (“Policy”) explains how we collect, use and disclose information in connection with your use of our website at www.roivant.com (“Website”). This Policy does not apply to our collection, use, or disclosure of data collected through other means.When you use our Website, you agree to our Terms of Use and collection, use, and disclosure of information about you as described in this Policy. Before you use or submit any information through this Website, please carefully review this Privacy Policy and our Terms of Use. IF YOU DO NOT AGREE TO THIS POLICY OR OUR TERMS, PLEASE DO NOT USE THIS WEBSITE. We will continue to evaluate this Policy as we update and expand the Website and our offerings, and we may make changes to this Policy accordingly. Any changes will be posted here and you should check this page periodically for updates. If we make material changes to this Policy, we will provide you with notice as required by law.Please note, you may also be subject to another privacy policy or other terms and conditions specific to a particular Roivant Sciences program or service (“Other Agreement”). Based upon your specific relationship(s) with Roivant Sciences, we may collect, use or disclose your information in ways described in more detail in one or more Other Agreements. To the extent the Other Agreement includes additional terms that are not covered by or are inconsistent with this Policy, the terms and conditions of the Other Agreement will supersede this Policy. Within this Policy you will find covered matters related to the following:

Information we collect

We collect and store information about you in multiple ways, including when you provide information directly to us and when we passively collect information from you, such as from your browser or device.

Information you provide directly to us

We collect and store all information that you provide to us when using this Website. You might provide information to us in a variety of ways such as (but not limited to) when you submit any of the following on our Website: information requests, business proposals, employment inquiries, and responses to surveys.The information you provide may include, but is not limited to: full name, home address, phone number, e-mail address and password, employment history, and your answers to background information questions.

How we use your information

We may use the Information we collect from and about you for the following purposes:

• complete any transactions you request online;
• provide, improve, and troubleshoot this Website;
• improve our products and services, and identify, develop, and offer new or expanded products and services;
• notify you about updates, products, services, and/or special offers from Roivant Sciences, its affiliates, and selected third parties;
• ask you to participate in brief surveys; and/or
• generate aggregate statistical studies and conduct research related to our products and services and the use of this Website.

We may combine information that we collect from you and about you (including automatically collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy.We may aggregate and/or de-identify information collected through the Website. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and/or others.Please note that, based upon your specific relationship(s) with Roivant Sciences, we may use your information in ways described in more detail in one or more Other Agreements.

Disclosure of your information

We may disclose your information to certain third parties with whom we have a direct or indirect business or contract relationship, under the following circumstances:To our subsidiaries or affiliates:We may disclose your information to other companies within the Roivant family of companies.To our partners:We may disclose your information to our partners, including other companies and academic institutions, such as those listed here.To service providers:We disclose your information with third parties who perform services on our behalf, including without limitation market research, data storage, data analysis and processing, and legal services. When you request other services, we will provide your information to third parties with whom we arrange for those services to be provided.To protect ourselves or others:We may also disclose information collected on this Website, in accordance with applicable law, to assert or defend our rights and property, to prevent harm to others, to collect a debt, or in response to legal processes such as subpoenas.To comply with the law:We may also provide (or reserve the right to provide) information to regulators, law enforcement authorities, courts, and other governmental authorities, consistent with applicable laws.For organizational transfers:As we continue to develop our organization, we may acquire, merge or partner with other organizations. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If any of Roivant Sciences’ assets are sold or transferred to a third party, customer information (such as your email address) would likely be one of the transferred business assets.Please note that, based upon your specific relationship(s) with Roivant Sciences, we may disclose your information in ways described in more detail in one or more Other Agreements.

Online Analytics

We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze the information discussed above, and to engage in auditing, research or reporting. The information (including your IP address) collected by various analytics technologies described in the “Cookies” section will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.If you receive email from us, we may use certain analytics tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Your Choices

You have the ability to opt out of receiving promotional communications from Roivant Sciences by emailing us at info@roivant.com or clicking the unsubscribe link in the relevant email. Remember, however, that even if you opt out of promotional communications, Roivant Sciences may still e-mail you in order to provide a product or service that you request.Except as otherwise specified in any Other Agreement, you can also access your information, update or correct factual errors in your information by sending us an e-mail at info@roivant.com. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.

Links to Third Party Sites

On our Website, we may link to third party websites, such as our partner companies, academic institutions, or employment listings. For example, to view a job description or apply to an open position, you may be rerouted to a third-party website. Please note, Roivant Sciences does not control the privacy policies or practices of these third-party sites. You should review those policies before providing any information.

Security

Roivant Sciences has established safeguards to help protect prevent unauthorized access to or misuse of your information, but cannot guarantee that your information will never be disclosed in a manner inconsistent with this Policy (for example, as a result of unauthorized acts by third parties that violate applicable law or relevant Web policies).

Children’s Privacy

This Website is not directed at children and we do not knowingly collect personal information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 13. If we become aware that we have collected personal information from children under the age of 13, we will take reasonable steps to delete it as soon as practicable. If a child provides us with this type of information online, please contact us to have the account deactivated by sending us an e-mail at info@roivant.com.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Although our Website currently does not recognize or respond to the various web browser Do Not Track signals, we do offer you choices to manage your preferences as described in the “Your Choices” section, above. To learn more about browser tracking signals and Do Not Track please visit https://www.allaboutdnt.org.

Contact Information

If you have any questions or concerns about this Privacy Policy or our privacy or security practices, you may contact us by e-mail at legalnotices@roivant.com or write to us in care of: Roivant Sciences, Inc., 151 West 42nd Street, 15th Floor, New York, NY 10036.  
This Privacy Policy is effective as of: September 13th, 2018.

SUPPLEMENTAL EUROPEAN/UNITED KINGDOM PRIVACY NOTICE

European Union Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and the United Kingdom’s Data Protection Act 2018 (together “GDPR”) require us as the data controller to provide additional and different information about its data processing practices to data subjects located within the European Economic Area (“EEA”) and UK.  If you are a data subject within the EEA/UK, this Supplemental European Privacy Notice applies to you in addition to any other information we provide regarding data privacy.

1. How we use your personal data

We will only use your personal data when applicable law allows us to so.  Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract that we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Necessary for scientific research purposes.

We may also use your personal data in the following situations, which are likely to be rare:

• Where we need to protect your interests (or someone else's interests).
• Where it is needed in the public interest or for official purposes.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation conduction clinical studies in mainland Europe.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need additional details about the specific legal ground that we are relying on to process your personal data where more than one ground has been set out in the table below.

2. Clinical Trial Data

We undertake clinical studies within the EU/UK and we will use information from subjects’ medical records and other health data in order to improve healthcare.  As a pharmaceutical organisation, we have a legitimate interest in using information relating to your health for research studies, when you agree to take part in a research study. Our exception to the general provision at Article 9(1) GDPR not to process special categories of data is that processing is necessary for scientific research purposes in accordance with Article 89(1) GDPR. This means that we will use your data when we act as the data controller for such studies, collected in the course of a research study, in the ways needed to conduct and analyse the research study. The Informed Consent Form will provide further detail of the processing of your personal data should you be a subject of a study. Your rights to access, change or move your information are limited, as we need to manage your information in specific ways in order for the research to be reliable and accurate. If you withdraw from the study, we will keep the information about you that we have already obtained. To safeguard your rights, we will use the minimum personally-identifiable information possible.

3. 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 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.

4. International Transfers of Personal Data

We are based outside the European Economic Area, so the processing of your personal data may involve a transfer of data outside the EEA/UK.  Information on how to contact the DPO can be found in Section 6 of this Notice (“How to Contact Us”).

Whenever we transfer your personal data out of the EEA/UK, 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 (“EC”) and the United Kingdom’s Information Commissioner’s Office (“ICO”).
• Regarding transfers to the US, we are required to incorporate the model clauses in agreements for transfer provided by the EC or the ICO in order to provide similar protection to personal data shared within Europe.

5. How long we retain your personal data

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.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

6. Your data protection rights

Under certain circumstances, visitors from within the EEA/UK have the following data protection rights:

• access to your personal data.
• correction of your personal data.
• erasure of your personal data.
• object to processing of your personal data.

If you wish to exercise any of the rights set out above, please contact our DPO at sar@thedpo.co.uk. You can also contact the Supervisory Authority in the country of your location within the EU/UK for advice or to make a complaint. Please be aware that your rights in relation to clinical research data may be limited.

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.

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.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.