FibroGen, Inc. (“FibroGen”) respects your privacy and is committed to protecting your personal data. FibroGen has established this Privacy Policy so that you are informed about how we treat any personally identifiable information that you provide to us in the course of using this website (regardless of where you visit it from) and to tell you about your privacy rights and how the law protects you.

This Privacy Policy will inform you of:

  1. Purpose of this Privacy Policy
  2. How you will be informed of updates to this Privacy Policy
  3. What personally identifiable information of yours we may collect from you through our website
  4. How we may use your personally identifiable
  5. Our policy regarding links to third party websites
  6. How your personally identifiable information is collected
  7. Legal basis for using your personal data< /li>
  8. International Transfers
  9. Security of our website
  10. How you can correct and update your personally identifiable information
  11. Your legal rights
  12. Glossary of the meaning of some of the terms used in this Privacy Policy

Purpose of This Privacy Policy

This Privacy Policy aims to give you information on how FibroGen collects and processes your personal data through your use of this website, including any data you may provide through this website.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Controller
FibroGen is made up of different legal entities, namely FibroGen, Inc., a Delaware corporation, with subsidiaries based in Hong Kong, China, Finland, and the Cayman Islands (the “FibroGen Group”). This Privacy Policy is issued on behalf of the FibroGen Group so when we mention “FibroGen”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the FibroGen Group responsible for processing your data. FibroGen, Inc. is the controller and is responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

Lisa Grubbs
409 Illinois Street, San Francisco, 94158, USA
lgrubbs@fibrogen.com

Supervisory Authorities
You have the right to make a complaint at any time to your respective supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Privacy Policy Updates

Due to the Internet’s rapidly evolving nature, FibroGen may need to update this Privacy Policy from time to time. If so, FibroGen will post its updated Privacy Policy on our website located at www.fibrogen.com so users are always aware of what personally identifiable information we may collect and how we may use this information. FibroGen encourages you to review this Privacy Policy regularly for any changes. Your continued use of this website will be subject to the then-current Privacy Policy.

Information Collection and Use

Personal data, or personally identifiable information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

You can generally visit our website without revealing any personally identifiable information about yourself. However, to access certain options and services we may ask you to provide certain personally identifiable information and without providing such personally identifiable information, you may be unable to access certain options and services. We (and our third party partners) generally collect personally identifiable information about you only if you voluntarily provide it to us and you have the option not to provide any personally identifiable information to us. In addition, we may use third parties to analyze data collected on our site. We may collect, use, store and transfer different kinds of personal data about you that we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, and gender.
  • News and Other Information by email. Information obtained from you from your request to subscribe to a newsletter or to receive other information, such as contact information (name and email address). We may use this personally identifiable information to deliver the newsletters that you have elected to receive.
  • Registration. Information obtained from you on registration forms used to process your requests for services and information, such as contact information (name, address, email address, telephone numbers), username, password, preferences, and feedback. This registration information may also be gathered if you register for certain services via fax or mail. We may use this information to send you emails to, e.g. verify your username and password, website updates, special offers, or other information responsive to the data that you provide to us. Additionally, we may refer to your personally identifiable information to better understand your needs and how we can improve our website. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website, products and services.
  • Employment. Information obtained from you on registration forms to process your requests to create an account to access job postings and to post your resume, such as contact information (name, email address, mailing address), password, username or code, employment history and any other personally identifiable information contained in your resume that you post to the website. We may use your personally identifiable information to send you emails to, e.g. to verify your username and password, for employee recruitment purposes and to respond to your requests for information.
  • Correspondence with FibroGen. You may use our site to contact our personnel through the email addresses provided on our website. If you communicate with or request information from FibroGen personnel, they will have your email address as well as whatever information or personal facts you choose to include in your email.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Links to Third Party Sites

Our website may contain links to other websites, plug-ins and applications that are not under the control of or maintained by FibroGen. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. Such links do not constitute an endorsement by FibroGen of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that FibroGen is providing these links to you only as a convenience, and you agree that FibroGen is not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites. When you leave our website, we encourage you to read the privacy notice of every website you visit.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or providing other information via our website. This includes personal data you provide when you:

  • Request our services;
  • subscribe to our publications or alerts; or
  • give us some feedback.


Automated technologies or interactions.
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Legal Basis for Using Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Minors
You must be 18 years of age or older to submit registration or survey information. If you are under the age of 18 and wish to register to obtain further information or be included in a survey, then your parent or legal guardian must register to obtain the information or to participate in the survey.

Cookies and GIF files
Some of our websites may use cookie technology to identify users who have previously visited so the user is recognized upon return, thereby saving them time while on our website. A cookie is a piece of data stored on the user’s hard drive containing information about the user. Once the user closes their browser, the cookie simply terminates. If a user rejects the cookie, they may still use our website. A cookie may be placed by us, or by vendors or service agencies who work with us or with our partners. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Log Files and Aggregate Information
We may track the total number of visitors to our website, the number of visitors to each page of our website, internet protocol (IP) addresses, and the domain names of our users’ Internet Service Providers, and we may analyze these data for trends and statistics in the aggregate. We retain IP addresses, and we may retain them together with personally identifying information.

We may use such information, individually or in the aggregate, to analyze trends, administer the website, track user’s movement, and gather broad demographic information for use. We may share this information with our corporate partners and contracted vendors to assist us in operating the website and to enable them to better understand FibroGen’s business.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Sharing and Disclosure
We may provide your personally identifiable information that we collect and the data generated by cookies to a parent, subsidiary or affiliate entity related to FibroGen, partner entities, and the vendors and service agencies that we may engage to assist us. Any organization to which we provide such personally identifiable information is required to respect the security of your personal data and keep your personally identifiable information confidential in accordance with this Privacy Policy. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Compliance with Law
We will also disclose your personally identifiable information if we reasonably believe we are required to do so by law, order, subpoena, regulation or other government authority (such as reporting safety information to the Food and Drug Administration). We will not sell your personally identifiable information to any other company or organization except we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which FibroGen participates or to a purchaser of all or substantially all of FibroGen’s assets. Such successor entity shall be bound by the terms and conditions of this Privacy Policy. We also reserve the right 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 websites.

International Transfers

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data to external third parties based outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
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  • >Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you wish to correct any information provided to us, you may update your contact information directly contacting us at info@fibrogen.com. You may also “opt-out” of receiving emails and other communications from us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

  • Internal third parties: Other companies in the FibroGen Group acting as joint controllers or processors and who are based in Europe and US and provide IT and system administration services and undertake leadership reporting.
  • External third parties: Service providers acting as processors based in Europe and US who provide IT and system administration services.