Last Updated: October 31, 2023
This policy does not address any data collected via any clinical trial conducted by enGene; and data collected in connection with clinical trials will be disclosed in trial-related documentation.
TABLE OF CONTENTS
1. Collection and Use of Personal Information
2. Information Collected Automatically
3. Disclosure of Personal Information
4. Lawful Basis for Processing
5. Third Party Links
7. Retention of Personal Information
8. Your Rights
1. COLLECTION AND USE OF PERSONAL INFORMATION
We collect personal information directly from you unless we have your consent or are legally permitted to collect your personal information indirectly.
Inquiries. If you contact us with an inquiry, we will ask for your name and contact information in order to respond to your inquiry.
Marketing Communications. We may offer the ability for you to sign-up to receive our newsletter and other promotional communications, in which case we collect your name and email address to send you the communications you have requested to receive. You can opt-out of receiving promotional communications from us by following the opt-out or “unsubscribe” instructions provided in our emails or on our website, or by contacting us as set out in the “Contact” section below. Please note that upon unsubscribing, you will continue to receive transactional and account-related electronic messages from us.
Job Applications. If you apply for a job at enGene you may be asked to provide us with certain personal information about yourself, such as your resume, cover letter, or similar employment-related materials. We use this information for the purposes of processing and responding to your application and assessing your suitability for current and future career opportunities.
We may collect other information that you choose to provide to us, or that we collect with your consent.
Use. We use the personal information we collect to provide our services. This includes:
• Providing services you request;
• Providing customer service and support;
• Communicating with you about products, services, and events that may be of interest;
• Communicating with you about events in which you participate;
• Aggregating or otherwise anonymizing your personal information for use for technical, research, and analytical purposes;
• Better understanding how you use the Website and our services, in order to improve the Website and our services and develop new products or services;
• Requesting and collecting feedback and responding to requests and complaints;
• Meeting our regulatory and other legal reporting obligations;
• Managing our business, including to maintain business records for reasonable periods, enforce our agreements, and collect amounts owing to us;
• To create anonymous, aggregated or de-identified data by removing information that makes the data that makes you identifiable.
2. INFORMATION COLLECTED AUTOMATICALLY
Log Files. When you use the Website, our servers automatically record certain information in server logs. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with the Website, domain names, landing pages, and pages viewed, mobile carrier, and similar information. Log files help us to monitor, analyze, improve and maintain the Website and to diagnose and fix technical issues.
Device Identifiers. When you access the Website using a mobile device, we collect information about your device contained in your mobile device’s “device identifier.” This device identifier includes information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We use this information to optimize the Website and fix technical issues.
Analytics. We may use third party service providers like Google Analytics to collect information about your use of the Website, such as the features used and time spent on the Website, to help us better understand our users and improve the Website. For information about how information is processed in connection with Google Analytics, please read the Google Analytics Policy here.
3. DISCLOSURE OF PERSONAL INFORMATION
Affiliates. We transfer personal information to our affiliates, including enGene Holdings Inc. and enGene USA Inc. for the purpose of supporting the business of enGene.
Service Providers. We may transfer personal information to third party service providers that provide certain services on our behalf, such as data hosting and processing, marketing, analytics, information technology services, and payment processing. Some of these service providers may be located outside of Canada, including in the United States, the United Kingdom, Bulgaria, Cyprus, and Spain. While outside of your jurisdiction of residence, personal information will be subject to applicable foreign laws, which may permit government and national security agencies to access your information in certain circumstances. For more information about the way in which our service providers treat personal information, please contact us as set out in the “Contact” section below.
Business Transaction. We may disclose personal information to parties in connection with a corporate transaction, such as a sale, financing or other disposition of all or part of our business or assets, for the purposes of evaluating and/or performing the transaction.
Other. We may disclose personal information to meet our legal and regulatory obligations or otherwise as permitted or required by law, including to comply with a subpoena or warrant, to law enforcement in connection with an investigation, to protect our rights and the safety and security of our employees, and to enforce our agreements and collect debts owed to us.
4. LAWFUL BASIS FOR PROCESSING
Depending on your jurisdiction, we rely on one or more of the following legal grounds (as appropriate) to process personal information:
• To enter and perform a contract with you or to perform any steps you require from us before entering into a contract;
• To pursue our legitimate business interests in establishing, managing, or concluding our relationship with you;
• Where you have specifically consented to us processing your personal information;
• To comply with our legal obligations and establish, exercise or defend our legal rights.
For more information on what our legal basis for processing is in relation to your personal information please reach out to us using the any of the methods outlined in the “Contact” section below.
Where personal information is processed with consent, you may (subject to contractual and legal restrictions) refuse to provide your consent, or choose to withdraw your consent, to our processing of your personal information by contacting us as described in the “Contact” section below. Note that if you refuse to consent, or withdraw your consent, to certain processing of your personal information, we may not be able to provide certain parts of our services.
5. THIRD PARTY LINKS
We protect personal information using safeguards that are appropriate to the sensitivity of the information. These safeguards may include measures to protect against unauthorized access, alteration, disclosure or destruction of personal information. We limit access to personal information to our employees and service providers who require access in connection with their role or function. Each of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. We keep our employees informed about our policies and procedures for protecting personal information. Despite these measures, since no system or security measure is completely secure, it is possible that personal information may be lost, stolen or accessed without authorization.
7. RETENTION OF PERSONAL INFORMATION
Personal information is maintained on our servers or those of our service providers and is retained as long as necessary for the fulfilment of the purposes for which it was collected, in accordance with prudent business practices on general document retention, or as otherwise required by law.
8. YOUR RIGHTS
You may request access to or correction of your personal information in our custody or control. You may also have the right, in specified circumstances, to object to our use of your personal information, to request the deletion of your personal information or restrict its use, to request a copy of the information you have provided to us to use for your own purposes, or to lodge a complaint with a supervisory authority. Your rights are subject to applicable legal restrictions and we may take appropriate steps to verify your identity before responding to your request. To exercise any of these rights, please contact us in writing using the contact information set out in the “Contact” section below.
For questions, inquiries or requests, please contact our Privacy Officer at email@example.com, call us at 514-332-4188 or send us at letter to: 7171 Frederick Banting, St-Laurent, Quebec H4S 1Z9.