Immunitrack ApS – PRIVACY POLICY

1. General terms and conditions
   • Immunitrack ApS provides tools for the research community to select or redesign drug candidates at the early stage of R&D and reagents to monitor lead drug candidates' effect on patients' immune systems. Immunitrack ApS is hereinafter referred to as "Immunitrack", "we", "our" and "us".
   • Immunitrack has a clear policy for processing the personal data which our customers and other visitors our website make available to us. We always process such personal data in a responsible manner, with respect for your private life and in accordance with the EU General Data Protection Regulation (GDPR). Customers and visitors are hereinafter referred to as "you" and "your".
   • We only process your personal data in accordance with the GDPR and other applicable legislation and/or in accordance with the consent which you have given to Immunitrack, if any.
   • Below you can read in detail about the personal data we collect, for which purposes we use it, how we process the personal data, who has access to the personal data, your rights and who you can contact about the collected personal data. We only collect personal data which you give to us and/or when you use our website. In all such cases you accept that our privacy policy and the terms and conditions stated herein apply to the processing or your personal data.
   • You can find more detailed information about processing of personal data on the website of the Danish Data Protection Agency, datatilsynet.dk.
   • If you have any further questions regarding the personal data which Immunitrack processes about you, please contact info@immunitrack.com.
2. Data controller and contact
   • Immunitrack is the data controller in relation to processing of your personal data and can always be contacted in the following way:Immunitrack ApS, company registration no. 32347908,Lærsø Park Allée 42-44 DK- 2100 Copenhagen Ø, Tel. +45 28 68 21 59, email: info@immunitrack.com.
3. Which personal data is collected by Immunitrack?
   • What is personal data?
     • Personal data is data which is directly or indirectly related to a person. Examples of personal data are name, address, telephone number and email address.
   • Which personal data is collected/processed by Immunitrack?
     • Immunitrack collects personal data in connection with marketing, purchase and delivery of products and services. This takes place i.e. when (i) you contact us for more information about our products, services and technology, (ii) when you fill in an order form on our website, or (iii) when you subscribe to our newsletters or ask us to contact you regarding our deliveries, products and services.
     • We collect personal data when you provide it to us through our website or by phone in connection with the above or from publicly available sources. This includes e.g. name, email, telephone/mobile number, company name and address as well as other information in connection with the use of our website.
     • We also process your personal data for registration and analysis purposes, management and optimization of our website in order to improve our services and target our communications with customers and other visitors to the website. Data collected in this connection is IP address, date and time for visit on our website, browser type and operative system of your computer and the websites you have visited as well as the status code of your server. We use this information to ensure the operation of our website and for security purposes. We also collect and analyze personal data as part of our traffic analysis regarding the behaviors of our visitors. The purpose is to avoid attacks, to identify security breaches and to optimize the website.
     • We use Google Analytics to track traffic. The processed website traffic data is usually transmitted to a server belonging to Google Inc., in the US, and stored there. The US is regarded as an unsafe third country in a GDPR context. However, Google Inc. has undertaken to comply with the EU-US Privacy Shield framework and thus to comply with the GDPR. If you wish to object to Google Analytics collecting personal data, you can download and install a browser add-on by using this link: https://tools.google.com/dlpage/gaoptout. The browser add-on notifies Google Analytics that they are not allowed to transmit personal data or information about visitors to our website.
     • You can read more about cookies and their purpose and how to delete and disable cookies in clause 11 below.

4. For which purposes does Immunitrack use your personal data?
   • Immunitrack only processes your personal data in accordance with applicable law. We use the information which you have given us for the following purposes:
     • For the delivery of the products and services which your company has purchased.
     • We use your email for marketing of our technology, products and services.
     • For sending electronic newsletters via the email stated by you.
     • For registration, analysis, management and optimization of our website and in order to communicate with our customers and visitors to our website and to improve our services and security of the website.
     • Finally we may use your personal data in order to contact potential and new customers as part of our marketing or delivery of our technology, services and products.

5. Legal basis for processing personal data
   • The legal basis for our processing of the personal data is article 6(1)(b) and 6(1)(f) of the GDPR. We may also use your consent as legal basis for processing of Personal data, see article 6(1)(a) of the GDPR.
   • Accordingly we process the personal data if it is necessary for the performance of a contract entered into by your company with Immunitrack, or due to the implementation of measures which you ask us to perform prior to entering into such a contract.
   • Our processing of the personal data may further take place if it is necessary in order for us to pursue a legitimate interest in processing personal data for example for the purpose of direct electronic marketing of our technology, products and services, including electronic newsletters. Finally, we may process the personal data subject to consent from you for one or more specific purposes such as sending our electronic newsletter.

6. How does Immunitrack store your personal data?
   • We endeavor to take good care of the personal data provided by you about yourself. From the moment we have received the personal data, you can trust us to process these data with the confidentiality and security required by law.
   • Immunitrack stores the personal data for as long as it is relevant in relation to the purposes set out above. This means that we store your personal data for as long as there is a contractual relationship between your company and us.
   • We are obligated to ensure that your personal data is correct and updated. Since our processing of the personal data also depends on this, we kindly ask you to inform us of relevant changes in your personal data. You can inform us of your changes on info@immunitrack.com.
   • Upon termination of the contractual relationship between your company and Immunitrack, we will continue to store your personal data for the following purposes:
     • Marketing of our technology, products and services for a period of up to five [5] years. However, you are at any time entitled to decline being contacted by us and request us to delete the personal data.
     • Storing of documentation pursuant to applicable requirements set by governmental and public authorities. In this case we will only store the personal data for as long as it is required pursuant to the government requirements in question.
     • We further store personal data in anonymous form for the use of statistics regarding our website and our technology, products and services.

7. Security
   • We do not encrypt the personal data stored by us, but we take good care of your personal data through access control and appropriate technical and organizational measures which are checked and updated on a regular basis.
   • We further see to it that your personal data is stored in such a manner that only relevant employees with a work-related need have access to your personal data. See also clause 8 below regarding business partners.
   • We will take all reasonable and necessary steps in order to ensure that the personal data is processed in a secure manner and in accordance with this privacy policy. Unfortunately, the transfer of personal data through the internet is not completely secure. Although we do our utmost to protect your personal data, we can consequently not guarantee the security of the personal data provided by you online, until the personal data in question has been received by us. We meet all relevant requirements for security and security processes in order to prevent unauthorized access, but you send your personal data to us at your own risk.
8. Business partners and other recipients
   • Immunitrack uses different business partners who supply services to Immunitrack. In this connection our business partners act as data processors, i.e. they process the personal data on our behalf and in accordance with written instructions on how and in what manner they are allowed to process the personal data.
   • We use IT suppliers in connection with general operation and maintenance of our website, hosting of our IT solutions and customer databases as well as in connection with customer support. In this connection, your personal data may be transferred to countries outside the EU/EEC (a "Third Country"). Transfer of your personal data to a Third Country may only take place if the EU Commission has determined that such Third Country has an adequate level of protection pursuant to existing EU data protection laws. You can read more about Google Analytics and transfer of personal data to Google Inc. under clause 3.2.
   • Our data processors and other suppliers cannot use the personal data for any other purpose than for the delivery of services to Immunitrack pursuant to our written instructions.
9. Your rights
   • Under the GDPR you have a number of rights concerning your personal data such as your right to access and information about our processing of your personal data, the right to request rectification or erasure of your personal data as well as your right to object to the processing of your personal data and to restrict processing hereof.
   • However, please note that your exercise of your rights may be limited according to our obligations according to law or in the interest of other persons' privacy or to protect trade secrets and intellectual property rights.
   • If you object to the processing of your personal data, we are no longer entitled to process such personal data, unless we are able to demonstrate that our compelling legitimate interest overrides your interests or your fundamental rights and freedoms. You are always entitled to object to the processing of your personal data for direct marketing purposes.
   • You have the right to withdraw consent to the processing of your personal data such as your consent to receive electronic newsletters. If your consent is withdrawn, this will affect our future processing of your personal data.
   • If you want to exercise your rights, you can contact us as stated under clause 2.
10. Complaint to the Danish Data Protection Agency
    • You have the option to complain about the processing of your personal data. The complaint must be filed to the Danish Data Protection Agency:
      https://www.datatilsynet.dk/generelt-om-databeskyttelse/klage-til-datatilsynet/.

11. Cookies
    • What are cookies:

• A cookie is a simple text file placed on your computer, tablet or smartphone by the website service.

• Why are cookies used:

• To help keeping track of where the users move on the website.
• To enable the users to start where they left off at their last visit to the website.
• To remember your log-in information for you.
• To remember the user's preferences.
• Marketing towards users after visits to the website.
• Optimization of the user-friendliness of the website.

• Cookies cannot see who you are, what your name is, where you live or whether the computer is used by one or more persons. Nor can cookies spread computer viruses or other malware.

• Our use of cookies:

• Immunitrack uses cookies to improve your experience of our website, to assess the use of the individual elements on the website and to support the marketing of our services on the website. You can read about our cookie policy here >>

• For how long are cookies stored:

• Cookies delete themselves after a certain number of months (may vary), but they are renewed after each visit.

• How to delete or block cookies: http://minecookies.org/cookiehandtering

• If you delete or block cookies, you must be aware that this may influence your use of our website and its functionality.

• Do you have any questions:If you have any questions regarding cookies and the processing of personal personal data, we kindly ask you to contact us on info@immunitrack.com.

12. Changes to our Privacy Policy
    • We regularly update and amend our privacy policy in order to regularly adapt it to applicable legislation and the technological development. In the event of material amendments we will inform you in the form of a visible notification on our website.

• The date of the latest update of our privacy policy is 30 June 2018.