Last update: 2021-08-11

The privacy of your data — and it is your data, not ours! — is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data: never have, never will.

What we collect and why

Our guiding principle is to collect only what we need. Here’s what that means in practice:

Identity & access

When you sign up for a Pharmanufacturing account, we typically ask for identifying information such as your name, email address, and maybe a company name. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We sometimes also give you the option to add a profile picture that displays in our products, but we do not normally look at or access that picture. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission either.

Billing information

When you pay for a Pharmanufacturing product, we ask for your credit card and billing address. That’s so we can charge you for service, calculate taxes due, and send you invoices. Your credit card is passed directly to our payment processor and doesn’t ever go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in the United States or VAT in the EU, to detect fraudulent credit card transactions, and to print on your invoices.

Geolocation data

We log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.

We also log full IP addresses used to sign up a product account. We keep this record forever.

Web analytics data — described further in the Website Interactions section — are also tied temporarily to IP addresses to assist with troubleshooting cases.

Website interactions

When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services.

Anti-bot assessments

We use CAPTCHA services across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your accounts and fill specific forms, the CAPTCHA service evaluates various information (e.g IP address, how long the visitor has been on the app, mouse movements) to check whether the data is possibly filled out by an automated program instead of a human. We retain these data via our subprocessor forever because they are used for anti-spam mitigation.

Cookies and Do Not Track

We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.

At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.

Voluntary correspondence

When you write Pharmanufacturing with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.

We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.

Information we do not collect

We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.

We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.

When we access or share your information

Our default practice is to not access your information. The only times we’ll ever access or share your info are:

To provide products or services you’ve requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. Having subprocessors means we are using technology to access your data. No Pharmanufacturing human looks at your data for these purposes unless an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases and when they happen, we look for root cause solutions as much as possible to avoid them from reoccurring.

To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.

When required under applicable law.

Kleos Pharma SARL is a French company and all data infrastructure are located in the European Union.

  • If European law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. In the event a government authority outside the European Union approaches Kleos Pharma with a request, our default stance is to refuse unless the European Union compels us to comply through procedures outlined in a mutual legal assistance treaty or agreement.
  • Similarly, if Kleos Pharma receives a request to preserve data, we refuse unless compelled by either a European Union legal entity, in which case we have to comply. In these situations, we notify affected customers as soon as possible unless we are legally prohibited from doing so.
  • If we get an informal request from any person, organization, or entity, we do not assist.
  • If we are audited by a tax authority, we may be required to share billing-related information. If that happens, we only share the bare minimum needed such as billing addresses and tax exemption information.

Finally, if Kleos Pharma SARL is acquired by or merged with another company we’ll notify you well before any info about you is transferred and becomes subject to a different privacy policy.

Your rights with respect to your information

At Kleos Pharma, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. Pharmanufacturing recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:

  • Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
  • Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
  • Right to Correction. You have the right to request correction of your personal information.
  • Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using Pharmanufacturing services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
  • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
  • Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data.)
  • Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
  • Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
  • Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
  • Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and directly updating your account information.

If you have questions about exercising these rights or need assistance, please contact us at Contact or at Kleos Pharma - 13 rue Primo Lévi, 75013 Paris - France. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.

If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.

How we secure your data

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted.

What happens when you delete data in your product accounts

In many of our applications, we give you the option to trash data. Anything you trash on your product accounts while they are active will be kept in an accessible trash can for up to 30 days (it varies a little by product). After that, the trashed data are no longer accessible via the application and are deleted from our active servers within the next 30 days. We also have some backups of our application databases, which are kept for up to another 30 days. In total, when you trash things in our applications, they are purged within 90 days from all of our systems and logs. Retrieving data for a single account from a backup is cost-prohibitive and unduly burdensome so if you change your mind you’ll need to do so before your data are deleted from our active servers.

We also delete your data after an account is cancelled. In this case, there is no period of data being kept in an accessible trash can so your data are purged within 60 days. This applies both for cases when an account owner directly cancels and for auto-cancelled accounts.

Location of site and data

Our products and other web properties are operated in the European Union. If you are located elsewhere outside of the European Union, please be aware that any information you provide to us will be transferred to and stored in the European Union. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.

Changes

We may update this policy as needed to comply with relevant regulations and reflect any new practices.