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We respect the privacy of visitors to our website. This Website Privacy Notice for the Bicycle Therapeutics group sets out the categories of your personal data we collect, how we collect it, what we use it for and with whom we share it in the context of providing this Site.
This Privacy Notice is intended to meet our duties of transparency under applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 as it forms part of United Kingdom law by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as subsequently amended (the “UK GDPR”). Please read the following carefully to understand our practices regarding your personal data.
By personal data we mean any information relating to you such as your name, contact details. Personal data does not include data which has been anonymised, such as data from equal opportunities monitoring carried out on an anonymised basis.
BicycleTx Limited will be the data controller in respect of the processing of any personal data collected through the website. In this Privacy Notice, “Bicycle”, “we”, “us” or “our” refers to BicycleTX Limited.. The data controller is responsible for deciding how personal data about you is used.
Should you have any questions about this Privacy Notice you can contact us by sending an email to privacy@bicycletx.com or write to us at:
BicycleTX Limited; Attention: General Counsel/Data Privacy Counsel
Blocks A & B
Portway Building
Granta Park, Great Abington
Cambridge
CB21 6GS
Bicycle Therapeutics Inc; Attention: Office Manager
35 Cambridgepark Drive
Suite 350
Cambridge
MA 02140
This Privacy Notice applies to personal data about you that we collect, use and otherwise process in connection with the use of our website.
We set out below the types of personal data about you which we may collect or create via your interaction with the website. In each case we have specified the purpose for which we use the relevant personal data and our ‘lawful basis’ for processing it. The law specifies certain ‘lawful bases’ for which we are allowed to use your personal data. Most commonly, we will rely on one or more of the following lawful bases for processing your personal data:
Where relevant, we have considered whether the interests or fundamental rights and freedoms of the individuals interacting with our website override our legitimate interests and have formed the view that they do not.
We will collect and process certain information about you that you provide to us and certain information we collect ourselves.
If you contact us and choose to provide personal data, such as your name, address, telephone number or e-mail address, we may use that information in order to respond to your correspondence or address the matters raised by you. It is for you to decide what personal data you provide.
The legal basis for processing this information is that it is necessary for the purposes of legitimate interests pursued by us, namely our interest in receiving and responding to correspondence from members of the public and addressing matters raised by members of the public.
Google Analytics uses cookies to distinguish you from other uses of our website. A “cookie” is a small file of letters and numbers that is stored on your browser or the hard drive of your computer to identify you as a unique user the next time you visit the site and to distinguish you from other users of our website. Cookies cannot read data off your hard drive but are used for site registration and identification. The Google Analytics cookies cannot be used by anyone but Google. When you open our website, you will be asked to accept the use of cookies. If you accept, you are agreeing to the use of cookies for the purposes described here. If you do not accept cookies, some pages on our website may not be able to access certain information on the website. Please note that third parties including, for example, advertising networks and providers of external services like web traffic analysis services may also use cookies, over which we have no control. You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. You may also opt-out by completing Google Analytics’ opt-out form accessible through this link: https://tools.google.com/dlpage/gaoptout.
Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
Where the information that we collect automatically on our website is personal data, the legal basis for the processing of this information is that it is necessary for the purposes of providing you the service and our legitimate interests in maintaining the safe operation of our website. We will request you consent for the purposes of improving our website and learning from how users interact with our website
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it (as identified above), unless we reasonably consider that we need to use it for another reason which 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.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
We may share your personal data with third parties where this is required by law, where it is necessary to perform our contract with you, or where we have another legitimate interest in doing so as outlined below:
Other members of our corporate group
We are part of a group of companies (the “Bicycle Therapeutics Group”) that includes Bicycle Therapeutics plc, BicycleTx Limited, BicycleRD Limited and Bicycle Therapeutics, Inc.
Certain functions of the Bicycle Therapeutics Group are centralised and conducted by members of the Bicycle Therapeutics Group other than us. We have a legitimate interest in benefiting from such centralisation and the services provided to us (as our data processor) by other members of the Bicycle Therapeutics Group. For example, other members of the Bicycle Therapeutics Group may assist in the recruitment process and may receive personal data in connection with such assistance.
We may also share your personal data with other entities in the Bicycle Therapeutics Group in the context of a business reorganisation or group restructuring exercise, for system maintenance support and for hosting of data.
Our service providers
We share personal data with Bicycle Therapeutics Group’s third-party service providers that perform services and functions at our direction and on our behalf. Our service providers are our IT service providers, recruitment service providers, our lawyers and our other advisers. We rely on service providers in order to effectively operate our business.
Analytics and search engine providers that assist us in the improvement and optimization of our website
We use a tool called “Google Analytics” as described above. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If all or any of our group companies or substantially all of their assets are acquired by a third party, in which case personal data may be one of the transferred assets.
Other third parties
We may need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process. We may disclose your personal data if we are required by law to do so or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or another legal process.
However, in these cases:
If you want further information on the specific mechanism used by us when transferring your personal data out of the UK, please contact our Privacy Coordinator (privacy@bicycletx.com).
The Bicycle Therapeutics Group has operations in the USA and in the UK. However, whenever it is being processed within the Bicycle Therapeutics Group, all personal data you provide to us will be stored on servers, which are provided and maintained by our processors, and which are located in the UK.
If members of the Bicycle Therapeutics Group located in the USA have access to information stored on servers in the UK, this will amount to a transfer of your personal data. We have put in place an intragroup data transfer agreement incorporating the Standard Contractual Clauses in respect of personal data that is transferred from members of the Bicycle Therapeutics Group in the UK to members of the Bicycle Therapeutics Group outside of the UK (such as Bicycle Therapeutics, Inc. who is located in the USA).
To establish additional practical safeguards for protection of your personal data, when transferring your information outside of the UK as part of the intragroup transfers described in this section, the transfer is made using an encrypted channel.
Once we have received your information, we will use appropriate technical and organizational measures to prevent unauthorised access, disclosure, loss or damage to your personal data.
Where the processing of your personal data is subject to the UK GDPR, you have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:
Your consent to processing of your personal data may sometimes form the legal basis of our processing of your personal data. Where this is the case, you can withdraw your consent at any time (without affecting the lawfulness of processing based on consent before your withdrawal of consent).
If you want to exercise one of these rights please contact using the contact details set out below.
By email: privacy@bicycletx.com
BicycleTX Limited; Attention: General Counsel
Blocks A & B
Portway Building
Granta Park Great Abington
Cambridge
CB21 6GS
Bicycle Therapeutics Inc; Attention: Office Manager
35 Cambridgepark Drive
Suite 350
Cambridge
MA 02140
You also have the right to make a complaint at any time to the UK data protection regulator, the UK Information Commissioner’s Office – whose contact information is below:
The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk/make-a-complaint/
Fees
You will not usually have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is to ensure that personal data is not disclosed to any person who has no right to receive it.
Any changes we make to this Privacy Notice in the future will be posted on this page or a successor page we flag as relevant for the purpose.
CHILDREN’S POLICY
This website is not intended for, or designed to attract, children.
Our site may, from time to time, contain links to and from the websites of our partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies or terms. Please check these policies before you submit any personal data to these websites.
This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information about this Privacy Notice, the practices of this website, or your dealings with this website, please do not hesitate to contact us.