LianBio Development (SG) Pte. Ltd. (“LianBio”, “our”, “we” or “us”) is committed to respecting and protecting your personal data and privacy.
We collect, use, disclose, process and care for (collectively, “process”) personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”) and other applicable laws. This SG Supplemental Privacy Notice (“SG Privacy Notice”) explains how we process personal data while meeting the requirements of applicable laws and professional standards.
Unless otherwise stated, this SG Privacy Notice applies in conjunction with any other data protection or privacy notice, policy or terms and conditions which we may publish or give to you from time to time.
We may amend or update this SG Privacy Notice from time to time. Please refer to our website (at www.lianbio.com) for the latest version.
Queries, requests (e.g. for access to or correction of personal data), notices (e.g. for withdrawal of consent), and complaints relating to your personal data may be sent in writing to us in the following manner with the information specified in this SG Privacy Notice:
Via Email: SG.DPO@lianbio.com
For more information about the PDPA, you may wish to refer to the website of the Personal Data Protection Commission (“PDPC”) at www.pdpc.gov.sg.
In this SG Privacy Notice, “personal data” means data about an identifiable individual. Whether data relates to an identifiable individual is determined with reference to the PDPA and any applicable guidelines issued by the PDPC.
We may collect personal data about you, directly from you or from another person or organisation, in the following circumstances:
(a) If you or your organisation enters into a service contract with us or our affiliates for the provision of services:
(b) If you send or provide your personal data directly to us (for example, through a letter, email or other communication);
(c) If your personal data is provided to us in order for us to provide services to you or your organisation;
(d) If you visit our website; and
(e) In such other circumstances as we may notify to you from time to time.
We may collect the following types of personal data about you when reasonably required for any of the purposes specified in this SG Privacy Notice:
(a) your full name, gender, age and contact details (e.g. telephone number and email address);
(b) information about your employment, in particular, your employer’s name, job title and business address;
(c) any information about you related to, or required for, a matter in respect of which we are engaged to provide services (e.g. height, weight, medical history, allergy history, adverse events, drug dosage, pregnancy reports, emergency contact and contact details, doctor’s information);
(d) your bank details for the purpose of processing payments (e.g. bank account number, account type, bank name);
(e) information about your employment history and academic background; and
(f) your online data when you access our website (including your IP address).
If you provide the personal data of any third party to us, you confirm that you have obtained the necessary consent from that third party to share and transfer his personal data to us, and for us to collect, store, use and disclose that personal data in accordance with this SG Privacy Notice.
We may collect, use and disclose personal data about you where permitted or required by written law or an order of court including (but not limited to) the following situations as further described in the PDPA:
(a) with your consent or deemed consent;
(b) in the vital interests of an individual;
(c) in the public interest or in relation to certain matters affecting the public;
(d) in the legitimate interests of an organisation (including but not limited to any affiliated entity);
(e) in relation to certain business asset transactions; and
(f) for research or business improvement purposes.
We may collect and use your personal data for the following purposes (as may be applicable):
(a) to provide services to you, your organisation or another person or organisation (including any necessary business communications in the provision of our services);
(b) to verify your identity;
(c) to manage and administer our relationship with you and/or your company (which includes, without limitation, conducting regulatory/safety checks and the processing of payments);
(d) to send you updates, newsletters, announcements, and any similar messages to keep you informed of biotech developments and our services;
(e) to respond to your queries, requests and complaints;
(f) to administer, operate, provide, maintain and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that unauthorised users do not access the information on our website);
(g) to process your application for employment or an internship;
(h) to conduct research and analysis to improve the services we provide;
(i) any other purpose which we notify you and obtain your consent or deemed consent for prior to processing your personal data for that purpose;
(j) any other purpose as required or permitted by law; and
(k) any other purpose which is ancillary or reasonably related to and/or required for any of the above purposes.
Subject to paragraph 2.3.1, we may disclose your personal data where reasonably required for any of the purposes specified in paragraph 2.2.1 (as may be applicable) to:
(a) our directors and employees;
(b) our affiliated entities working with us or on our behalf for the purposes described in this SG Privacy Notice;
(c) our business partners, licensor, third-party service providers, data intermediaries and agents;
(d) governmental authorities; and
(e) any other third parties we may notify you from time to time.
We may produce data in aggregated and/or de-identified form from the personal data we hold. Where such data has been sufficiently anonymised and no longer constitutes personal data, we may use such data for statistical, analytical or other purposes or disclose such data to other parties at our discretion.
Where personal data is sent to us in circumstances where we did not request for or expect the submission of the data (including situations where personal data sent to us includes specific items of data which we did not request for), we reserve the right to process the data in such manner and for such purposes as we reasonably consider appropriate in the circumstances, taking into account the purpose for which they were sent to us (if apparent to us).
Subject to any specific data protection notice we may give to you and the terms and conditions of any contract which may be agreed between us, if you provide any personal data to us, whether directly or indirectly through another party, you agree and consent to our collection, use and disclosure of such data in accordance with this SG Privacy Notice.
You may withdraw any consent given or deemed to have been given in relation to the collection, use and disclosure of your personal data by giving us not less than fifteen (15) business days prior written notice via email to our email address as stated in this SG Privacy Notice (above). Your notice withdrawing consent must clearly state the following:
(a) your full name;
(b) your address, telephone number or email address (so that we may contact you concerning your notice or if we require additional information to process your notice);
(c) the personal data affected by your notice; and
(d) the purposes or activities you are withdrawing consent for.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In the event you withdraw consent or deemed consent for the collection, use or disclosure of your personal data, we shall (subject to paragraph 3.4) cease to collect, use and/or disclose your personal data (within the scope of your withdrawal of consent), in which case we may not be in a position to continue providing the services which you had engaged us to provide.
Withdrawal of consent or deemed consent does not affect:
(a) the legality of the use of your personal data prior to your consent being withdrawn;
(b) our collection, use and disclosure of your personal data without your consent as permitted or required by law;
(c) any liability, debt or obligation accrued by you prior to the date of such withdrawal; or
(d) the terms and conditions of any contract agreed between us (save as it may relate to our collection, use or disclosure of your personal data with your consent).
You may, at any time, request to access your personal data in our possession, or enquire about the ways in which your personal data may have been used, disclosed, stored or processed by us for the past year.
You may also, at any time, request to correct any error or omission in your personal data records.
You may make a request for access to, or correction of, your personal data which is in our possession or under our control in accordance with (and subject to) the PDPA and the relevant regulations made thereunder.
A request under paragraph 4.1 shall be made in writing and sent via email to our address as stated in this SG Privacy Notice (above). Your request must state the following:
(a) your full name;
(b) your address, telephone number or email address (so that we may contact you concerning your request or if we require additional information to process your notice);
(c) that you are making the request under the PDPA;
(d) whether you are requesting for access to your personal data or for a correction to be made to an error or omission in your personal data; and
(e) the specific personal data or correction you are requesting.
We will aim to respond to your request and inform you of the actions to be taken as soon as reasonably possible and in any case no later than 30 calendar days after your request. However, we reserve the right not to respond to manifestly unfounded or excessive requests, or any frivolous and/or vexatious requests.
Depending on the nature of your request and subject to any contract or other terms and conditions agreed between us, we may impose a reasonable fee to provide access to the personal data you requested. In such an event, we shall inform you of the fee payable for your confirmation and acceptance prior to further processing your request.
We shall take reasonable steps to ensure personal data collected by us or on our behalf is accurate and complete if:
(a) it is likely to be used to make a decision that affects you; or
(b) it is likely to be disclosed to another organisation.
Where you or your organisation provides your personal data directly to us, we shall be entitled to assume that it is accurate and complete.
We shall protect personal data in our possession or under our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks and the loss of any storage medium or device on which personal data is stored.
We shall notify you (in accordance with and subject to the PDPA) in the event of a data breach affecting your personal data which may cause significant harm.
We may retain your personal data as long as reasonably required for any of the purposes specified in this SG Privacy Notice and for any other legal or business purpose permitted by law.
We shall cease to retain documents containing personal data, or remove the means by which the personal data can be associated with particular individuals, when it is reasonable to assume that retention is no longer necessary for the purpose for which the data was collected or used or for any other legal or business purpose.
By providing us with your personal data, you understand and agree that your personal data may be transferred to servers located outside Singapore for processing by us, our affiliates and/or any other organisation which we may choose, in accordance with this SG Privacy Notice.
If we transfer personal data to a country or territory outside Singapore, we shall ensure that it is protected to a standard of protection that is at least comparable to the protection under the PDPA in the manner prescribed in the relevant regulations under the PDPA.
To facilitate your use of our website and services, we may employ the use of session cookies. Session cookies, which expire at the end of a browser session, are only used to collect and store technical data. Most internet browsers are automatically set to accept cookies. You can manage your cookie settings through your internet browser settings or mobile device settings.
An IP address is an assigned number, similar to a telephone number, which allows your computer (or other electronic device) to connect to and communicate with websites over the Internet. It enables us to identify which organisations have visited this website. When you visit our website, our server may record your IP address together with the date, time and duration of your visit. This information does not enable us to identify you individually. We use this information to compile statistical data on the use of our website to track how users navigate through our site. We do this so we can evaluate and improve our site.
Please note that we do not currently meet the threshold applicability requirements of U.S. state privacy laws, including the California Consumer Privacy Act (“CCPA”). If we meet those thresholds in the future, we will update this Notice to include applicable disclosures related thereto.
Without prejudice to an individual’s rights under the PDPA, nothing in this SG Privacy Notice shall create or confer any legally enforceable right whether by way of contract, tort, equity or otherwise under the law.