Privacy Notice

About MEI Pharma

MEI Pharma Inc. is San Diego-based oncology company focused on the clinical development of novel therapies for cancer.  We process personal data in different contexts and we do so by respecting your privacy, as part of our unwavering commitment to ethical and responsible practices.  We process personal data collected through our website (“Website”), we also gather personal data for marketing purposes, and for conducting our day-to-day business, including clinical trials.

MEI Pharma, Inc.
3611 Valley Centre Drive, Suite 500
San Diego, CA 92130

About this Privacy Notice

This Privacy Notice is designed to help you understand what information we gather from you when you visit our website (“Website”) or interact with us, and what we do with that information.

This Privacy Notice applies to information collected by MEI Pharma through our Website or in the course of our business activities, including information from our suppliers, their personnel and other health care professionals, and researchers that participate in studies or clinical trials that we sponsor (“You”). We have a separate privacy policy for trial subject’s information collected in the context of clinical trials and for our employees.

Personal Data We Collect

Personal data as used herein means all information that can directly or indirectly identify you or other individuals. We collect different types of personal data depending on the context of your interactions with MEI Pharma. 

MEI Pharma collects the following types of personal data:

  • Personal data collected through the Website:  including contact information provided directly by you when you submit information through the Website, through requesting investor information or subscribe to our news alerts.  Some information is also collected automatically through the use cookies, including Internet Protocol (“IP”) address, browser type, and web log data.  For additional information see our Cookies Policy.
  • Personal data from job applicants: when you apply for a job posting with MEI Pharma, information collected includes your contact details, resume, employment history and other information that you submit for our consideration.
  • Personal data from health care professionals, researchers and personnel from Clinical Research Organizations and our vendors:  we collect personal data from the different entities and professionals that participate on the studies or clinical trials that we sponsor, including their contact details and qualifications or resumes. 
  • Personal data collected from public sources:  including from internet sites such as clinicaltrials.gov to ensure we conduct the proper due diligence on professionals, physicians, etc. for purposes of clinical trials.
  • Other personal data provided directly by you:  we collect your contact details if you request information or submit questions to us, including other personal data that you decide to share with us.

Use of Personal Data

The purposes for which we collect and use your personal data varies depending on the type of relationship you have with us, such as if you are a Website user or applying for an open job position. 

We will use your personal data:

  1. for our everyday business purposes, including recruitment practices and notices of any legal updates;
  2. to provide you with requested information; 
  3. to operate the Website, and to analyze it for trends and statistics; for additional information see our Cookies Policy;
  4. to provide company informational materials and content, as well as other communications that may include invitations to events hosted or sponsored by MEI Pharma. 
  5. To identify clinical trial subjects and investigators and conducting clinical trial and research activities;
  6. To comply with laws and regulations, including court orders, or in the course of litigation or defense from legal claims; 
  7. To protect the rights, property or safety of MEI Pharma, or any of our respective business partners, or other third parties in accordance with Data Privacy Laws;
  8. To cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behavior that is illegal or harmful to other users, including suspected fraud, or situations involving potential threats to the physical safety of any person;
  9. To share your personal data with other uses that you specifically authorize us based on your consent.

Disclosure of Personal Data

At times, MEI Pharma engages third party contractors or service providers to help us accomplish our business objectives.  There are other circumstances where we are required by law to disclose personal data to third parties such as public bodies or judicial authorities. 

Disclosures to Third Parties Assisting in Our Operations.  We engage with contractors and service providers for the following services: email solutions, providing cloud hosting services, analyzing data and usage of the Website, or providing support and maintenance services for the Website, as well as agents, legal, regulatory, audit and other professional and business advisors.  Such recipients may be located in the United States (US) or in other jurisdictions such as the European Economic Area (EEA) or Asia Pacific.  If the engagement involves the transmission of personal data, we require the service provider to sign a data processing agreement consistent with this notice before any data is disclosed.  These companies do not have any independent right to share or use this information. 

Disclosures required by law.  We may provide information about you, to respond to subpoenas, court orders, search warrants, legal processes or governmental regulations or inquiries, or to establish or exercise our legal rights or defend against legal claims.  

Other Parties with Your Consent or at Your Direction.  In addition to the disclosures described in this Privacy Notice, we may share information about you with third parties when you consent to or request such sharing.

Business Transfers.  We may share your personal data with another business entity in connection with the sale, assignment, merger or other transfer of all or a portion of MEI Pharma’s business to such business entity. 

Privacy Settings/Opt-Out/Changes/Access

At certain locations on the Website where information about you may be requested, you are offered the opportunity to opt-out of receiving communications from MEI Pharma. You may also review and request changes to your personal data that MEI Pharma has collected, including the removal of your personal data from MEI Pharma’s databases in order to prevent receipt of future communications, by contacting us at privacy@meipharma.com.

If you wish to opt out of promotional emails, you may do so by following the “unsubscribe” instructions in the emailorby contacting us at privacy@meipharma.com

You can also contact us at privacy@meipharma.comfor your opt-out and access rights related to clinical trials.

Transfers of Personal Data Outside of Your Local Jurisdiction

If you are located outside the United States and you interact with our Website or provide us personal data, then your personal data may be transferred to the United States or to other jurisdictions.  However, we provide appropriate safeguards to ensure the same level of protection of your personal data.

We transfer your personal data to the United States (US) whenever you send us information through our Website or interact with us.  If you are located in the European Economic Area (EEA) or Switzerland, please note that the US has not obtained adequacy status from the European Union, and accordingly the level of protection of your personal data is not deemed equivalent to the one in Europe.  In the context of our studies or clinical trials, your personal data can be transferred to other jurisdictions with less stringent data privacy laws.  However, we provide appropriate safeguards to ensure the same level of protection of your personal data including the use of standard contractual clauses (data transfer agreements), that can be provided on request.

Data Protection Rights

If you reside or otherwise find yourself in the territory of the European Economic Area (EEA) or Switzerland, we are committed to facilitate the exercise of your rights granted by the data protection laws of these territories.

For the purposes of the European Data protection law we are controllers of your personal data.  You can contact our Data Protection Officer or our EU Data Representative (see Section 9) with any inquiries you may have regarding the processing of your personal data. 

MEI Pharma assigns a legal basis for each data collection and use:

·     For our everyday business purposes, including our studies and clinical trials, legal communications and responses to your requests:  legitimate interest to conduct our day-to-day business, communicate with you or to respond to your inquiries.

·     Recruitment practices:  Necessity to enter into a contract.

·     Information collected automatically (cookies):  consent when legally required and legitimate interest of MEI Pharma to analyze trends and website statistics.

·     Corporate communication and informational communications:  legitimate interest of MEI Pharma to send marketing material, or consent when you directly request this information.

·     Compliance with laws and regulations:  compliance with legal obligation.

·     Protect the rights, property and safety of MEI Pharma or third parties:  legitimate interest of MEI Pharma or other third parties to protect their rights, property or safety.

·     Uses that you specifically authorize us:  consent.

MEI Pharma recognizes your Data Privacy Rights:

·     Right to access, rectification, restriction of processing, erasure, and data portability: we provide you with access to your own personal data.  In addition, we will rectify your personal data when it is incorrect or inaccurate, and we will ensure the right to erasure, portability and to restriction of processing when these rights are not incompatible with other legal obligations. 

·     Right to object: for all MEI Pharma, Inc. corporate communications, you can opt-out anytime, and free of charge.  The right to object for other processing activities will be balanced to ensure that it is not incompatible with local regulations or our legitimate interests. 

·     Right to withdraw consent at any time.  When we use your information based on your consent, you have the right to withdraw such consent at any time.

·     MEI Pharma does not engage in automated decision making, including profiling.

·     Right to lodge a complaint with your supervisory authority.  If you are not satisfied with our response or how we process your personal data, you can complaint to the data protection authority of your habitual residence.

For your rights in the context of clinical trials, please contact us at privacy@meipharma.com.

Data Privacy Rights requests should be submitted as follows: 

·      Opt-out of corporate communications:  If you wish to opt out of informational emails, you may do so by following the “unsubscribe” instructions in the email. 

·      To enforce the rest of your rights,or for any further privacy-related question or concerns you may have, you can contact us by email at privacy@meipharma.comor our EU Data Representative at info@dpoconsultancy.nl.  We will attend to your request in a timely manner within 30 days after receiving your request.  If for any reason we need to extend this period of time, we will contact you.

·      You also have the right to lodge a complaint with a supervisory authority:  A list of the European authorities is available hereand the contact of the Federal Data Protection and Information Commissioner of Switzerland is available here.

Data Protection Officer and EU Data Representative

MEI Pharma has appointed a Data Protection Officer and an EU Data Representative in the European territory.

For any inquiries with regard to this notice or about our handling of your information, you can contact our Data Protection Officer at:  privacy@meipharma.com or our EU Data Representative at info@dpoconsultancy.nl.

Children's Privacy Protection

You should be at least 18 years old to use this Website.

The Website does not seek to collect personal information from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before providing any personal information to us via this Website.  

Notwithstanding the foregoing, individuals under 18 years of age who have provided personal data to us through the Website may have the personal data that they have provided to us through the Website deleted by contacting us at privacy@meipharma.comand requesting deletion.  

Retention Periods

MEI Pharma retains personal data for the length of time required to fulfill the purpose for which the data was collected.

According to our retention policy, we only keep personal data in our records as long as they are necessary for the purposes they have been processed.  The retention periods are established considering the purposes defined in this privacy notice, all relevant legal requirements and the context in which we process your personal data.  For instance, we keep the personal data of prospective employees that have not been successful in joining the company only for the duration of the hiring process, unless they consent to us keeping their data for future hiring campaigns.  In addition, personal data collected automatically through the Website through cookies can be kept for 1 year.  See our Cookies Policy.  After the retention period expires, the personal data is deleted.

Security

MEI Pharma understands that storing our data in a secure manner is essential.  We take reasonable precautions to keep all information secure against unauthorized access and use.

MEI Pharma stores personal data by using reasonable physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification. 

In addition, ourinformation security team has developed policies, standards and procedures to support and enforce preventive and detective operational controls to ensure the confidentiality, integrity, and availability of MEI Pharma’s data.

Please note, however, that while MEI Pharma has endeavored to create a secure and reliable website for users, the confidentiality of any communication or material transmitted to/from the Website or via email cannot be guaranteed. 

The Website may contain links to other websites.  MEI Pharma is not responsible for the privacy practices or the content of those websites.  This Privacy Notice applies solely to information collected by the Website.  Users should be aware of this when they leave the Website, and should review the privacy statements of each third-party website. 

Notice to California Residents

Disclosure to Third Parties

Under California Civil Code sections 1798.83-1798.84, California residents who use our Website are entitled to request a notice describing what categories of personal information we share with third parties for marketing purposes.  We would only share your information with your consent. If you are a California resident and would like a copy of this notice, please submit a written request to the contact address below.

MEI Pharma does not take action in response to “do-not-track” signals.

Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates, although web browsers incorporate and activate this functionality in different ways, and it is not always clear whether users intend these signals to be transmitted.  There currently is disagreement, including among participants in the leading internet standards-setting organization, concerning what, if anything, websites should do when they receive such signals.  MEI Pharma currently does not take action in response to these signals, but, if and when a standard is established and accepted, we may reassess how to respond to these signals.

Changes to this Privacy Notice

This Privacy Notice may be revised from time to time as we add new features, as laws change, and as industry privacy and security best practices evolve.

If we update the Privacy Notice, we will let you know about any changes that we consider material by placing a note on the Website.  The most current version of the Privacy Notice will always be available on the Website.  You can check the "effective date" posted to see when the Privacy Notice was last updated.  

Contact

If you have any questions about this Privacy Notice or about our handling of your information, please contact MEI Pharma at privacy@meipharma.com

MEI Pharma, Inc. (att: legal department).

3611 Valley Centre Drive, Suite 500, 

San Diego, CA 92130, 

USA