Applied Therapeutics, Inc., (“Applied Therapeutics” or “we”) has established this Privacy Policy to describe how we use information that we collect via our services, including this web site (the “Site”). Please be sure to read this entire Privacy Policy before using or submitting information to us. Applied Therapeutics reserves the right to change the Privacy Policy terms at our discretion. If we do change the terms of this Privacy Policy in a manner that materially alters the ways in which we collect or use information that is or could reasonably be tied to you (“Personal Data”), we will notify you by placing a notice on our Site. Please check back from time to time to review this policy.
If you are a participant in a clinical trial held in healthcare centers in the European Union, please see Section 12 (Study Subjects Privacy Policy). Other sections of this Privacy Policy do not apply to you.
Applied Therapeutics may collect the following categories of Personal Data through the Site:
We collect this Personal Data from a variety of sources. We collect information in connection with certain of our products and services, such as when you visit our Site or enroll in our patient assistance program (collectively, the “Services”) and from other sources, such as your healthcare provider.
If you desire to take advantage of certain services, information, and materials provided only to registered users of the Site, you will be required to register, and in registering will be required to provide us with Personal Data. Please note that if you decline to provide Personal Data, you may not be able to take advantage of certain services we provide to our registered users.
Applied Therapeutics may use Personal Data for the following:
We also use Personal Data in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law. We may aggregate or de-identify any information collected about you and we may use that aggregated or de-identified information for any purpose. To the extent we de-identify any data originally based on Personal Data, we will maintain and use such data only in de-identified form and will not attempt to re-identify the data.
We may share the categories of Personal Data listed above with agents, affiliates, contractors, or business partners of Applied Therapeutics in connection with services that these individuals or entities perform for, or with, Applied Therapeutics. These agents, affiliates, contractors, or business partners have agreed to use Personal Data only to provide services for Applied Therapeutics. For example, we may provide Personal Data to an entity that hosts our business databases or that provides data processing services for us, so that we can send you information that you have requested from us.
We may also disclose Personal Data in response to demands or orders from courts or other government authorities, including in connection with actions brought by third parties pursuant to subpoena or other legal process. We may also use or disclose Personal Data if we deem it reasonably necessary to protect the rights or property of Applied Therapeutics, including this Site, its customers, or other Site users, e.g., in response to a denial of service attack or the introduction of malicious software to the Site. We may disclose Personal Data to potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business.
Applied Therapeutics will keep Personal Data for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your Personal Data for a period of time that enables us to:
We may collect Personal Data using technologies and methodologies that enable tracking, such as “cookies” and similar technologies. “Cookies” are small pieces of information that a website transfers to the hard drive of a visitor’s computer for record-keeping purposes. “Cookies” provide visitors a personalized experience on the Site by enabling us to determine unique preferences and trends based on visits to the Site and to other websites.
With respect to analytics cookies, we may use third-party analytics services on our Site, such as those of Google Analytics. To learn more about Google Analytics and how to opt out, visit: https://policies.google.com/technologies/partner-sites.
Interest-Based Advertising
When you use our Site, both we and certain third parties (such as advertising networks, digital advertising partners, and social media platforms) may collect information about your online activities over time and across third-party websites. Such information may be used to provide you with advertising about products and services tailored to your interests. We also may obtain information for this purpose from third-party websites on which our ads are served. You may see certain ads on other websites if we engage third-party ad-buying networks. Through such ad-buying networks, we can target our messaging to users through demographic, interest-based, and contextual means. The information our ad networks may collect on our behalf includes data about your visits to websites that serve our advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in these ad networks. This process helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising, visit Your AdChoices.
For more information, review the Self-Regulatory Principles for Online Behavioral Advertising (“Principles”) of the Digital Advertising Alliance. You can visit Ad Choices for information on how to indicate your preferences, including opting out of interest-based advertising with participating entities. Note that opting out of interest-based advertising does not mean you will no longer see advertisements from us or on our Site because your information may have been collected and shared prior to your opt-out request, the ads may not be customized to your specific interests, or the ads may be served based on your interactions with other companies and their websites. When you opt out of receiving interest-based advertisements through the links above, cookies and other technologies on our Site may still collect information about your use of our Site, including for analytics, fraud prevention, and any other purpose permitted under the Self-Regulatory Principles.
Depending on where you live, and subject to certain exceptions, you may have the following rights with respect to your Personal Data:
You may submit requests to exercise your other rights by emailing us at info@appliedtherapeutics.com.
You may also have the right to appeal a refusal to take action on your request by emailing us at info@appliedtherapeutics.com with the subject line “Appeal of Rights Request Decision.”
We have put in place physical, technical, and administrative procedures designed to safeguard Personal Data and to prevent unauthorized access to Personal Data.
This website is not intended nor designed for use by children under the age of 18 years. Applied Therapeutics does not knowingly collect Personal Data from any individual under the age of 18 years.
This site does not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across websites or other online services. If we do so in the future, we will describe how we do so in this Privacy Policy.
This site may contain links or references to other websites. Please be aware that we do not control other websites and that, in any case, this Privacy Policy does not apply to those websites. We encourage you to read the privacy policy of every website you visit.
If you have any questions, comments, or concerns about this Privacy Policy or about the information practices of this site, please contact us at:
Applied Therapeutics
545 Fifth Avenue, Suite 1400
New York, NY 10017
212.220.9226
info@appliedtherapeutics.com
IMPORTANT: This Section is only applicable to participants in clinical trials held in healthcare centers in the European Union. If this is not your case, this Section will not be applicable to you.
PLEASE READ THIS SECTION CAREFULLY
The purpose of this Section is to inform you about the data processing activities that we carry out as data controllers. This is without prejudice to the policies provided to you by other independent controllers that may be involved in the clinical trial, such as medical centers or the investigators, as appropriate.
Who is the data controller?
Applied Therapeutics, Inc. (hereinafter, “AT” or “we“), as the sponsor of the clinical trial in which you have decided to participate, is the data controller of certain personal data referred to you, and produced in the context of said trial. AT is domiciled in 545 Fifth Avenue 14th floor, New York NY 10017, USA, and its email address for privacy purposes is dpoprivacy@appliedtherapeutics.com.
AT has appointed a representative in the European Union, namely, EDPO (European Data Protection Office), with an address avda. De Europa 26 ATICA 5, 2a planta, 28224 Pozuelo de Alarcón, Madrid, Spain and email address privacy@edpo.com and online form at: https://edpo.com/gdpr-data-request/. AT has also appointed a data protection officer with the following e-mail address: dpoprivacy@appliedtherapeutics.com.
What personal data do we process? What sources do we use?
Although we do not have direct access to such data (except for coded data as detailed below), we are controllers of personal data that may be processed on our behalf (i.e. as processors) by the medical center, and/or the investigation team conducting the clinical trial and/or our Contract Research Organization (“CRO”) and/or monitor, as the case may be. Besides, our representative in the European Union may provide us with the personal information it handles as our representative. Please note that medical centers and/or investigators involved in the clinical trial may provide AT with direct access only to coded data, meaning data where elements that allow the direct identification of the trial subject are replaced with a code associated with the clinical trial participation data. This code is guarded by the medical center. Only in truly exceptional cases (e.g. in a life-threatening event), we may directly access data that enables us to identify you with the assistance of the medical center and/or the investigation team. Consequently, the main categories of data that we process are:
Your personal data is processed in the United States, a country that does not provide a protection considered adequate by the European Union authorities from a data protection standpoint. However, we have adopted appropriate safeguards to protect your personal data. In particular, AT, the medical center and/or the investigation team, as applicable, has entered into a transfer agreement based on the Model Clauses approved by the European Commission (you may access to the Model Clauses through this URL: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj). You can request information in this regard through the contact address above.
For what purposes and on which bases do we process your data?
The processing of your personal data (including health data) is necessary for AT, as the sponsor of the clinical trial in which you have freely decided to participate, to be able to carry out the same, and to exercise its functions as a sponsor. This includes:
The legal basis for the processing activity described above is to comply with legal obligations in the context of biomedical research, for instance Regulation (EU) No 536/2014, and local laws of the country in which the clinical trial takes place. Moreover, note that this processing activity (including processing of your health data) is necessary for the scientific research purpose of the trial in line with art. 9.2(j) of the General Data Protection Regulation and necessary for reasons of public interest in the area of public health (art. 9.2 (i) of the same legal text).
Note that in some countries, the legal basis for the processing activities (a) to (e) above is:
Who are the recipients of the data?
Your personal data will not be shared with third parties, except in case of legal obligation (e.g. to public bodies in charge of monitoring clinical trials – this may include US authorities, based on important reasons of public interest in complying with US laws) or, where strictly required, with the site undertaking the clinical trial (when acting as a controller) for the purposes and based on the legal bases above. Additionally, your personal data may be accessed by service providers acting in our name and on our behalf, such as the trial’s monitor, our representative in the European Union, computer maintenance providers, etc.
How long will we keep your personal data?
Your pseudonymized data will be kept for 25 years in compliance with applicable clinical trial regulations, at the due authority’s disposal. After such term, the data will be kept during the statute of limitation of applicable legal actions, in accordance with the applicable laws. Data will be retained under conditions that guarantee their due security and maintenance.
What rights do you have with regard to the processing of your data?
You have the right to obtain confirmation as to whether your personal data are being processed and, if so, to have access to them and to know certain information (purposes, categories of data processed, etc.) (right of access). You also have the right to request the rectification of inaccurate data (right to rectification), as well as the erasure of data when, among other reasons, they are no longer necessary for the purposes for which they were collected (right to erasure). Under certain circumstances, you may request that the processing of your data be restricted and that it is processed only for the purpose of exercising or defending claims (right to restriction of processing).
You also have the right to object to the processing at any time if the processing is based on the public interest or legitimate interest (right to object). In addition, you have the right to receive personal data in a structured, commonly used and machine-readable format and to transmit them to another data controller, in the cases provided for by law (right to data portability).
You may exercise your rights at: dpoprivacy@appliedtherapeutics.com.
Please note, however, that when data are used in biomedical research in an anonymized or pseudonymized form (using codes), we may not be able to identify you due to the requirements of biomedical research laws. In addition, in some cases, data protection laws may provide for exceptions to the exercise of these rights. For this reason, we recommend that you first try to exercise your rights with the investigators of the medical center. In any case, when we receive a request, we undertake to make every effort to provide a proper response, including by referring it to the medical center, if appropriate.
In addition, you may address or file a complaint with the data protection supervisory authority of your EU Member State. You can find information on such authority in this URL: https://edpb.europa.eu/about-edpb/board/members_en.
