1. INTRODUCTION
At Breye Therapeutics ApS, Agern Alle 24, 2970 Hørsholm, CVR no. 40279865 (“Breye Therapeutics”), we understand the importance of processing personal data securely and confidentially. This Privacy Policy is intended for our website visitors and other persons with whom we interact with via email.
Breye Therapeutics is committed to complying with the requirements and obligations relating to the processing of personal data under applicable law, including the General Data Protection Regulation (“GDPR”). We have therefore implemented appropriate procedures to protect your personal data.
If you have any question to this privacy policy or if you wish to exercise your data subject rights pursuant to Chapter III of the General Data Protection Regulation (“GDPR”) and according to section 6 of this privacy policy, please contact Breye Therapeutics by email to [email protected].
2. PROCESSING ACTIVITIES
2.1 Website visitors
2.1.1 What personal data do we process and for what purposes
When you visit Breye Therapeutics’ website, https://breye.com/ (“Website”), Breye Therapeutics will be processing personal data about you via cookies, such as online identifiers. We use cookies i.a. to improve your user experience and the functionality of our website, to marketing purposes, and to remember your preferences. You can read more about our use of cookies in our cookie policy which can be accessed by clicking on the icon located in the bottom left corner.
2.1.2 Legal basis
The legal basis for the processing of your personal data is Breye Therapeutics’ legitimate interests, which, in Breye Therapeutics’ view, are not overridden by your fundamental rights and freedoms as provided in Article 6(1)(f) GDPR. The legitimate interests pursued by Breye Therapeutics are to make a well-functioning website available and to provide a unique user experience. In certain cases, the legal basis is your consent, which we will request when you visit the Website, in accordance with Article 6(1)(a) of the GDPR.
2.1.3 Disclosure of personal data
Breye Therapeutics will in certain cases disclose your personal data to other group companies, business partners or other partners for business purposes. Such third parties include, inter alia, social media providers as specified in para. 4 below.
Additionally, your personal data will be processed by certain third parties, among them the provider of the technical solution behind our Website and the cookie solution, on Breye Therapeutics’ behalf and in accordance with Breye Therapeutics’ instructions and the obligations laid down in the data processing agreement concluded with Breye Therapeutics. These data processors may not process your personal data for their own purposes.
2.1.4 Storage of personal data
Personal data collected through the use of social media will be deleted as soon as the content in question is deleted or when you remove your reaction to our content (like, share, etc.). For details, see para. 4 below.
Personal data collected through cookies during visits to our website is stored for varying periods depending on the type of cookie and the purpose of the cookie. Please see the cookie policy and the cookie pop-up in this regard which can be accessed by clicking on the icon located in the bottom left corner.
2.2 Contacts at suppliers, other business relations etc.
2.2.1 What personal data do we process and for what purposes
As a contact person at one of our suppliers or other business relations, Breye Therapeutics will process personal data about you when you communicate with Breye Therapeutics for example via email in the context of Breye Therapeutics’ contractual relationship with the company by which you are employed or in the context of the conclusion or termination of a contract. Breye Therapeutics will process general personal data about you, including your name and surname, email address, telephone number, job title, etc.
2.2.2 Legal basis
The legal basis for the processing of your personal data is Breye Therapeutics’ legitimate interests, which, in Breye Therapeutics’ view, are not overridden by your fundamental rights and freedoms as provided in Article 6(1)(f) GDPR. The legitimate interests pursued by Breye Therapeutics are the performance of our contractual obligations, the maintenance and strengthening of our business relationships, the invoicing of the services provided to Breye Therapeutics by the company you are employed by and vice versa, and for documentation purposes where an agreement is concluded by email.
In certain cases, the processing of your personal data is necessary to comply with a legal obligation imposed on Breye Therapeutics for example in connection with the storage of accounting records under the Danish Bookkeeping Act. In such cases, the legal basis is Article 6(1)(c) GDPR.
2.2.3 Disclosure of personal data
Breye Therapeutics will in certain cases disclose your personal data to other group companies, business partners or other partners for business purposes. Such third parties include, inter alia, social media providers as specified in para. 4 below.
In certain specific cases, e.g., in the context of disputes, including where disclosure is necessary for the establishment, enforcement or defence of Breye Therapeutics’ legal claims, Breye Therapeutics may disclose your personal data to advisors or other relevant third parties, if deemed lawful and necessary.
2.2.4 Storage of personal data
If you are a contact person of one of Breye Therapeutics’ suppliers or other business relations, Breye Therapeutics will process personal data about you for as long as Breye Therapeutics is communicating with you because you are our contact person, for three years after termination of the contractual relationship, or until your personal data is no longer necessary for the establishment, exercise or defence of legal claims.
If your personal data are included in Breye Therapeutics’ accounting records, e.g., in connection with invoicing, your data will be stored for five years from the end of the financial year to which the accounting records relate. This is to ensure compliance with our legal obligations under the Danish Bookkeeping Act.
2.3 Contacts of other persons who contact us by email
2.3.1 What personal data do we process and for what purposes
When you contact us by email, we will process the personal data you provide to us in order to handle your inquiry. This will typically be your name, telephone number, email address, and the contents of your inquiry.
Breye Therapeutics will not process special categories of personal data (sensitive personal data) about you, e.g., health data, unless you have provided such data yourself, in your inquiry to us. Breye Therapeutics kindly asks that you do not send any sensitive personal data to us.
2.3.2 Legal basis
The legal basis for the processing of your personal data is Breye Therapeutics’ legitimate interests in providing our services and developing our business, which in Breye Therapeutics’ view, are not overridden by your fundamental rights and freedoms as provided in Article 6(1)(f) GDPR.
2.3.3 Disclosure of personal data
In certain specific cases, e.g., in the context of disputes, including where disclosure is necessary for the establishment, enforcement, or defence of Breye Therapeutics’ legal claims, Breye Therapeutics may disclose your personal data to advisors or other relevant third parties, if deemed lawful and necessary.
2.3.4 Storage of personal data
Inquiries will be deleted after the inquiry is resolved, unless a longer retention period is required for documentation purposes, e.g., to a dispute, including for the establishment, exercise, or defence of legal claims.
3. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES (COUNTRIES OUTSIDE THE EU/EEA)
In certain cases, your personal data may be transferred to countries outside the EU/EEA. Breye Therapeutics will ensure that the transfer takes place in accordance with applicable data protection law. This entails that any party outside of the EU/EEA that will receive your personal data will ensure an adequate level of protection, for example, by entering into the EU Commission’s Standard Contractual Clauses (“SCCs”) with Breye Therapeutics. Breye Therapeutics will ensure the implementation of additional safeguards if deemed necessary on a case-by-case basis.
You can request a copy of the legal basis for the transfer by contacting [email protected].
4. SOCIAL MEDIA
Our Website features a direct link to the social media LinkedIn and an embedded YouTube video. When you visit our social media page on LinkedIn or use the direct link to LinkedIn provided on our Website, the social media provider will collect and process personal data about you. Such collection and processing of personal data will take place whether you have a social media profile or not. When watching the embedded YouTube video on our Website, YouTube will also collect and process personal data about you by means of cookies, provided you have consented to the use of cookies. Please note that we have no influence on the amount of personal data that LinkedIn or YouTube collects about you and that neither LinkedIn nor YouTube’s processing of your personal data is covered by this Privacy Policy. For more information, please refer to the social media providers respective privacy policies below:
LinkedIn: https://www.linkedin.com/legal/privacy-policy
YouTube: https://policies.google.com/privacy?hl=en
Breye Therapeutics is joint data controller together with LinkedIn when processing your personal data in connection with visits to our social media page on LinkedIn. This means, i.a., that you can contact both Breye Therapeutics and LinkedIn if you wish to exercise your rights under the GDPR. The social media provider has primary responsibility for ensuring compliance with the GDPR and for responding to requests to exercise data subjects’ rights. If you have a social media profile, you can exercise your rights through your account settings.
5. YOUR RIGHTS
We have taken a number of measures to protect your personal data and safeguard your rights. Because of our processing of personal data about you, you will have the rights described below. However, some rights apply only in certain circumstances. The Danish Data Protection Agency has issued guidance on the rights of data subjects. For details about your rights, please see here (please note that the guidance linked to is only available in Danish).
- You have the right to request access to, and receive a copy of, the personal data that we are processing about you and, in this context, also to receive a range of additional information.
- You have a right to have incorrect personal data about yourself rectified and to have incomplete personal data completed.
- You have the right to request that personal data about you be deleted in certain circumstances, e.g. if processing is based on your consent and you choose to withdraw that consent.
- You have a right to have the processing of your personal data restricted, e.g. if the accuracy of the personal data is contested.
- Where our processing is done automatically and is based on your consent or the performance of an agreement with you, you have the right to request to receive the personal data that you have provided to us in a structured, commonly used, and machine-readable format and to request the transmission, where technically feasible, of such data to another controller.
- You may object to the processing of your personal data by us, including in particular in relation to direct marketing.
- You may request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
- You may withdraw your consent to the processing of your personal data at any time. Withdrawal of your consent will not affect the processing of your personal data that took place before the date of withdrawal, however.
If you wish to exercise any of the above rights, or if you wish to withdraw your consent, please feel free to contact us at [email protected].
6. QUESTIONS OR COMPLAINTS
If you have any questions about this Privacy Policy or if you wish to exercise any of your rights as explained above or if you disagree with the way we process personal data about you, please contact Breye Therapeutics at [email protected].
If you disagree with the way in which Breye Therapeutics processes your personal data, you may file a complaint with the Danish Data Protection Agency, using the contact details that are available here. However, we hope that you will contact us first, using the below contact details, so that we may try to come to an agreement.
7. AMENDMENTS TO THIS PRIVACY POLICY
This Privacy Policy is regularly updated and amended, including as required on account of changes to statutes, practices and rules and regulations on the data protection area. You are advised, therefore, to always stay up to date on the contents of this Privacy Policy.
Last changed: 21 November 2023