Haya Therapeutics SA (also «we», «us») collects and processes personal data that concern you but also other individuals («third parties»). We use the word «data» here interchangeably with «personal data».
In this Privacy Notice, we describe what we do with your data when you use https://hayatx.com («website»), obtain services from us, interact with us in relation with a contract, communicate with us or otherwise deal with us. When appropriate we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice.
If you disclose data to us or share data with us about other individuals we assume you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.
This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR») and the Swiss Data Protection Act («DPA»). However, the application of these laws depends on each individual case.
Haya Therapeutics SA, in Epalignes («Haya») is the controller for Haya’s processing under this Privacy Notice, unless we tell you otherwise in an individual case.
You may contact us for data protection concerns and to exercise your rights under Section 11 as follows:
Haya Therapeutics SA
Route de la Corniche 5
Startlab / Biopôle
We process various categories of data about you, including current but also previous versions where information changes over time. The main categories of data are the following:
Technical data: When you use our website, we collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems. We generally keep technical data for maximum of 14 months. In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 11). Technical data as such does not permit drawing conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation with user accounts, registrations, access controls or the performance of a contract.
Communication data: When you are in contact with us by e-mail, telephone, or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we have to determine your identity, we collect data to identify you (for example a copy of an ID document). We generally keep this data for 12 months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least 10 years.
Master data: With master data we mean the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes, such as name and contact details, and information about, for example, your role and function, your bank details, your date of birth, customer history, powers of attorney, signature authorizations and declarations of consent. We process your master data if you are a customer or other business contact or work for one (for example as a contact person of the business partner), or because we wish to address you for our own purposes or for the purposes of a contractual partner (for example as part of marketing and advertising). We receive master data from you (for example when you make a purchase or as part of a registration), from parties you work for, or from third parties such as contractual partners, associations and address brokers, and from public sources such as public registers or the internet (websites, etc.). We may also collect master data from our shareholders and investors. We generally keep master data for up to 10 years from the last exchange between us but at least from the end of the contract. This period may be longer if required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. For contacts used only for marketing and advertising, the period is usually much shorter, usually no more than 2 years from the last contact.
Contract data: This means data that is collected in relation with the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback. We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but also from third-party sources (for example credit information providers) and from public sources. We generally keep this data for up to 10 years from the last contract activity but at least from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.
Other data: We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation with administrative or judicial proceedings. We may also collect data for health protection (for example as part of health protection concepts).Moreover, we collect and process data about our shareholders and other investors, in addition to master data, including information for registers, in relation with the exercise of their rights and with events (for example general meetings). The retention period for this data depends on the processing purpose and is limited to what is necessary. This ranges from a few days for many of the security cameras, to usually a few weeks in case of data for contact tracing and visitor data that is usually kept for 3 months, to several years or longer for reports about events with images. Data relating to you as a shareholder or investor is kept in accordance with corporate law, but in any case for as long as you are invested.
Much of the data set out in this Section 3 is provided to us by you. You are not obliged or required to disclose data to us except in individual cases, for example within the framework of binding health protection concepts (legal obligations). If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data.
As far as it is not unlawful we also collect data from public sources or receive data from public authorities and from other third parties.
We process your data for the purposes explained below. Further information is set out in Sections 11 and 12 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.
We process your data for purposes related to communication with you, in particular in relation with responding to inquiries and with the exercise of your rights (Section 10) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data. We keep this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.
We process data for the conclusion, administration and performance of contractual relationships.
We may also process your data for security and access control purposes.
We process personal data to comply with laws, directives and recommendations from authorities and internal regulations («Compliance»).
We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.
We may process your data for further purposes, for example as part of our internal processes and administration.
Where we ask for your consent for certain processing activities, we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 11. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.
Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. This also includes compliance with legal regulations, where compliance is not recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA, Swiss law).
Where we receive sensitive personal data (for example health data), we may process your data on other legal basis, for example, in the event of a dispute, as required in relation with a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.
In relation with our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:
Service providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers. This may include health data. For the service providers used for the website, see Section 11.
Contractual partners including customers: This refers to customers and our other contractual partners as this data disclosure results from these contracts. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. This may include health data. These recipients also include contractual partners with whom we cooperate.
Other persons: This means other cases where interactions with third parties follows from the purposes set out in Section 4.
All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).
As explained in section 6, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed both in Europe and in the United States and Canada; in exceptional cases, in any country in the world.
Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.
We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 11. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.
We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.
Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, to profiling carried out for direct marketing purposes and to other legitimate interests in processing.
To help you control the processing of your personal data, you have the following rights in relation with our data processing, depending on the applicable data protection law:
If you wish to exercise the above-mentioned rights in relation with us, please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).
Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.
If you do not agree with the way we handle your rights or with our data protection practices, please let us (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country.
We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits. This Section informs you about this.
In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers ) that assign a specific identification number to you or your browser (so-called «cookie»).
We use these technologies on our website and may allow certain third parties to do so as well. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.
We distinguish the following categories of «cookies» (including other technologies):
We currently use offers from the following service providers (where they use data from you or cookies set on your computer for advertising purposes):
We may operate pages and other online presences («fan pages», «channels», «profiles», etc.) on social networks and other platforms operated by third parties and collect the data about you described in Section 3 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.
For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects rights and how you can exercise them or obtain further information. We currently use the following platforms:
This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.
Last updated: May 2021