Please read this Statement carefully before using our Website or submitting any information to us. Using our Website and submitting information is voluntary, and, by using our Website, or submitting information, you acknowledge that you understand and agree to our collection and use of your information as described in this Statement. If you do not agree to any of the provisions in this Statement, please do not use the Website or disclose or submit any information to us.
All individuals whose responsibilities include the processing of personally identifiable information (“Personal Information”) on behalf of Turning Point are expected to protect that data by adherence to this Statement.
1. Transparency/Notice – Personal Information We Collect and How We Collect It
The types of Personal Information we may collect (directly from you or from third-party sources) and our privacy practices depend on the nature of the relationship you have with Turning Point and the requirements of applicable law. We endeavor to collect information only relevant for the purposes of processing such information as permitted by applicable laws. Below are some of the ways we collect information, how we use it and the legal bases for such collection and uses.
When you use this Website, Turning Point will collect only the Personal Information you provide us, if any, such as title, name, address, phone number, email address, username, and Internet Protocol (“IP”) address. We also may collect any Personal Information you provide us when you apply for employment via our Website, or when you contact us via e-mail for information or assistance, including the content of your e-mail.
Some of the ways that Turning Point may collect your Personal Information include:
- The Website, surveys, business or marketing events.
- When you use the Website, you may have opportunities to sign up to receive specific information and we may ask for your contact information, so that we can send you specific information you have requested.
- When you apply for employment via our Website, or when you contact us via e-mail for information or assistance, we may obtain the information you provide, including the content of your e-mail, your name, contact information and other details included in your request.
- As you navigate the Website, certain passive information may also be collected, including internet protocol addresses, cookies, navigational data, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, the date and time you access our Website, and the Internet address of the website from which you linked directly to our Website.
- From time to time, Turning Point may collect Personal Information to enable you to use online social media resources offered either by Turning Point or a third party as part of the Website. Generally, online social media resources are interactive tools that enable you to collaborate and share information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.
2. Use and Disclosure of Personal Information
2.1 Depending on how you interact with Turning Point, we and our third-party service providers may use Personal Information in a variety of ways, including:
- Providing Information and Services You Requested. Turning Point may use the Personal Information about you to provide you information that you may request. Turning Point may also use your Personal Information to deliver a specific program to you, when you enroll to receive the program. Such use may include: (a) generally managing your information; (b) responding to questions, comments and requests; (c) providing access to certain areas and features of our Website; and (d) permitting you to register for events or participate in webinars.
- Administrative Purposes. Turning Point may use the Personal Information about you for its administrative purposes, including, without limitation, to: (a) measure interest in our Website and programs; (b) perform internal quality control; (c) verify identity; (d) send communications regarding the Website, programs or services.
- Sharing Content with Friends or Colleagues. The Website may offer various tools and functionality. For example, the Website may include functionality that will allow you to forward or share certain content with a friend or colleague. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Turning Point or any other third parties for any other purpose.
- Pseudonymous Data. Turning Point may use and share your anonymized or aggregated information within Turning Point or with third parties for public health, research, analytics and any other legally permissible purposes. Anonymized or aggregated information is not Personal Information.
- Other Uses. Turning Point may use your Personal Information for other purposes disclosed to you at the time you provide Personal Information or with your consent.
2.2 Sensitive Personal Information. Before disclosing Sensitive Personal Information (a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections; examples include race or ethnic origin, religious or philosophical beliefs; genetic and biometric data; information about one’s health or sex life; information relating to the commission of a criminal offense; financial account numbers; and government issued identifiers) to a third party or processing Sensitive Personal Information for any purpose you have not authorized, Turning Point will try to get your explicit consent (opt-in).
3. Mobile Devices, Cookies, Pixel Tags/Web Beacons, and Analytics Information
3.1 Mobile Devices. Turning Point may provide websites and online resources that are specifically designed to be compatible and used on mobile devices. Turning Point will collect certain information that your mobile device sends when you use such websites or online resources, like a device identifier, user settings and the operating system of your device.
Mobile versions of the Website may require that users log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, Turning Point may enable Individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to us to enable Individuals to access user accounts and to enable us to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. We may use personal or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Statement or in other notices we provide.
3.3 Pixel Tags/Web Beacons. We may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the browser type and language; the device type; geographic location; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we or our third party-service providers may use “format sensing” technology, which allows pixel tags to let us know whether you received and opened our email.
3.4 Analytics Information. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Website, and to develop website content. This analytics data is not tied to any Personal Information.
4. Website Users outside of the United States
4.1 Turning Point is based in and our Website is hosted in the United States of America (USA). Please be aware that the Turning Point Website is directed towards users who reside in the USA. It is not our intent to gather personally identifiable information from individuals residing outside the USA. If you are outside of the USA, by submitting personally identifiable information to us through the Website, you are consenting to the collection, storage and processing of that information in the USA and to any country to which we may transfer your information for the purposes described in this Statement. If you are outside the USA, please note that the USA may have different laws concerning the privacy of personally identifiable information than your country of residence and may not provide the same level of data protection as the laws of your country.
4.2 European Data Subjects. If you are from the EU, the processing of any personal data you provide us is governed by the EU’s General Data Protection Regulation (“GDPR”) data privacy laws. GDPR requires us, as the data controller, to provide certain information concerning our processing of personal data, which is contained within this Statement. Any processing of your data is upon the legal bases stated herein.
You have the right to request access to your personal data, to have your personal data corrected, restricted or deleted, and to object to our processing of your personal data. Where you have consented to Turning Point’s processing of your Sensitive Personal Information, you may withdraw that consent at any time and opt out by sending an email to firstname.lastname@example.org. Your rights may be subject to various limitations under the GDPR. If you wish to exercise any of these rights, or if you have any concerns about our processing of your personal data, please contact us in any of the ways listed in the section “Contact Us”. You have the right to file a complaint concerning our processing of your personal data with your national (or in some countries, regional) data protection authority. The EU Commission list can be found at: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
4.3 Privacy Shield Statement. Turning Point complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union and Switzerland to the United States (collectively, the “Privacy Shield”). Turning Point has certified to the U.S. Department of Commerce that we adhere to the principles underlying the Privacy Shield (the “Principles”). The United States Federal Trade Commission (FTC) has jurisdiction over our compliance with the Privacy Shield and we are subject to the FTC’s investigatory and enforcement powers. Information regarding the Privacy Shield program and evidence of our certification can be found at https://www.privacyshield.gov/.
Our accountability under the Privacy Shield found by visiting https://www.privacyshield.gov/article?id=3-ACCOUNTABILITY-FOR-ONWARD-TRANSFER, for the Personal Information we receive and subsequently transfer to third parties is described in the Principles. In summary, we remain responsible and liable under the Principles if third-party agents that we engage to process your Personal Information on our behalf do so in a manner inconsistent with the principles, unless we can prove that we are not responsible for the event giving rise to any harm you may incur.
4.4 Website Limitation. This Statement applies to personal data collected via our Website. If you have provided personal data to us through some other means besides our Website (for example, in connection with a clinical study sponsored by Turning Point in Europe), you will have received a separate notice concerning your personal data. Please refer to that notice first if you have any concerns about our processing of your personal data, as that notice will contain important information and a designated contact person for concerns – but you can always contact us (see contact information below).
5. Data Retention and Storage
Turning Point retains Personal Information we receive through this Website as described in this Statement for as long as you use our Website or as necessary to fulfill the purpose(s) for which Personal Information was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.
6. Security of your Information
Turning Point is committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while Turning Point uses reasonable efforts to protect your Personal Information, Turning Point cannot guarantee its absolute security. By using the Website, you agree and acknowledge that Turning Point shall not be liable or responsible if any information about you is intercepted, accessed, and/or used by an unintended recipient. If you have reason to believe that the security your communications or Personal Information has been compromised, please immediately notify us immediately at: email@example.com.
7. Changing Your Information
If you later decide that you do not want your Personal Information used for the purposes described in this Statement, you may contact us to request removal of your Personal Information from our database. For EU Individuals, any such request will be subject to GDPR limitations, as indicated above. You may also contact us to correct or update any Personal Information you have provided us. You may also “opt-out” of receiving e-mails and other communications from us by using the unsubscribe feature included in the e-mails we send.
This website is not intended or designed to attract or collect any information from or about children under the age of 13. We do not collect information about the age of any visitors to our website. If you are a parent or guardian of a child under the age of 13 who you believe may have provided personally identifiable information to us, please contact us and we will promptly delete such information, if any, from our databases.
9. Links to Other Websites
As a convenience to our visitors, the Website may contain links to a number of websites that we believe may offer useful information. The privacy policies and procedures described herein do not apply to such websites or their content, or to any collection of your personal information after you click on links to such third-party websites.
10. Contact Us
If you have questions regarding this Statement, want to submit a request, or for other reasons anticipated above, please contact us at:
Turning Point Therapeutics, Inc.
Attn: Privacy Officer
10628 Science Center Drive, Suite 200
San Diego, California 92121
Turning Point will respond to any concerns and try to resolve any privacy issues in a timely manner. If you are an EU citizen and feel that Turning Point is not abiding by the terms of this Statement, please contact Turning Point at the contact information provided above. If any request remains unresolved, you may contact the national data protection authority for your EU Member State. Turning Point has further committed to cooperate with a panel established by a European Union data protection authorities (“DPA”) and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) with respect to unresolved Privacy Shield complaints concerning Personal Information transferred from the EU and Switzerland to the United States. Under certain circumstances, certain Individuals may choose to invoke binding arbitration to resolve any Privacy Shield disputes that have not been resolved by other means.