Privacy

Effective December 2019


Xgene Pharmaceutical Inc. (“Xgene”, “our”, “us” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users using our Xgene platform (the “Service”) or our websites, accessible at www.xgenepharm.com, and newsite.xgenepharm.com (collectively, the “Site”). This Privacy Policy applies only to information that you provide to us through the Site and Service. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site. You are advised to consult this policy regularly for any changes.

As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates internationally.

For details regarding choices we offer in connection with your information and our information practices, please see “Your Choices” below. If you have any questions about this Privacy Policy, please contact us at eldon.chang@xgenepharm.com.


Information Collection


Our primary goals in collecting information are to provide and improve our Site, Service, features and content, to administer your use thereof, and to enable users to enjoy and easily navigate the Site and Service.


Information You Provide Us


When you register with us as a Xgene subscriber or when you choose to create your own profile webpage, we will ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to, your name, phone number, credit card or other billing information, email address and business postal addresses. We use your Personal Information mainly to provide the Service and administer your inquiries.

We also collect the other information that you provide as part of registration and the administration and personalization of your profile webpage (e.g., without limitation, zip code and individual preferences) and use of the Service (“Non-Identifying Information”). For example, we will collect information related to your internet search and browsing activity in order to develop a profile of your professional expertise.


Information We Collect Automatically When You Use the Services


When you access or use our Services, we automatically collect information about you, including:

  • Log Information: We collect log information in connection with your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our websites.
  • Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
  • Location Information: We may collect information about your location through various technologies, including by deriving approximate location from IP address and by collecting more precise location via our mobile apps.


Information Collected by Cookies and Other Tracking Technologies


We and our service providers use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness.


Information We Collect About You From Other Sources


We may also obtain information from other sources. For instance, our customer service application may provide us with a link to your social media profile(s).


Information We Collect From Public Sources


If you have a profile, resume, or CV on a publicly-available website, we may collect information about you either directly or through third-party providers of such public information. This information is limited to your professional qualifications and contact information.

The information we collect about you will include personally identifiable information such as name, education, qualifications, work history, work title, contact information, and experience. We do not collect sensitive data (e.g., health, political affiliation) from any of these sites.

We may infer other characteristics about job candidates such as additional skills, so that recruiters and hiring managers can be more targeted when approaching candidates. We may infer “likely” personal characteristics of candidates, including gender, ethnicity, and/or country of origin (e.g. from first and last names, country where they attended university, service in armed forces, etc.) to help recruiters easily find highly-qualified diverse candidates.

All the information collected about job candidates is used to allow sourcing professionals to find professionals faster, smarter and better by using predictive algorithms and data-backed insights.


Information About Children


We do not knowingly collect any personal information directly from children under the age of 18. If we discover we have received any personal information from a child under the age of 18, we will take reasonable steps to delete that information as quickly as possible. If you find information on Xgene about anyone under the age of 18, contact us at eldon.chang@xgenepharm.com.


Use of Customer Information


We may use the data we collect to communicate with you. For example, we may send you promotional emails about Xgene or alert you of service changes via our product support system. We also track when you open messages from us. This tracking helps us improve our communication with you. If you do not wish to receive emails from us, you may change your preferences via the links provided in the emails.

Additionally we may use the information we collect about you to:

  • Provide, maintain and improve our Services and develop new products and services;
  • Provide and deliver the services you request;
  • Send you technical notices, updates, security alerts, confirmations and invoices, and other support and administrative messages;
  • Respond to your comments, questions and requests and provide customer service;
  • Communicate with you about products, services, offers, promotions, rewards and information we think will be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Company and others; and
  • Personalize and improve the Services and provide content or features that match your profile or interests.


Use of Professional Profile Information


All the information collected about professionals is used to allow our customers to find professionals faster, smarter and better by using predictive algorithms and data-backed insights. If anyone wishes to change or restrict the use of their information by the Services, follow the steps in the Your Choices section below.


Sharing Information


We may share information about you as follows or as otherwise described in this Privacy Policy:

  • With service providers that carry out work on our behalf, for example, third parties we partner with to invite you to our training or web events;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Company or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  • Between and among Company and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; 
  • If you have integrated your applicant tracking system (ATS) or customer relationship manager (CRM) software with Xgene, we will share data with those systems when you export a list; and
  • With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.


Emailing Via Xgene


As part of the Service, Xgene subscribers may communicate with other Xgene subscribers and non-registered users through use of their accounts. Where Xgene subscribers have selected the option of adding one or more email addresses to an online form, the message they create in the corresponding template will be sent from Xgene to those email addresses on their behalf. These email addresses will be stored in the address book the Xgene subscriber creates and will be used only for the purpose of sending the email communication to the addressee.


Analytics Services


We may use third parties, such as Google, to provide analytics services for our websites and online services. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, and links clicked. This information may be used to, among other things, analyze and track use of Xgene, determine the popularity of certain features on Xgene, and better understand your online activity. In particular, these analytics services help us to make Xgene an even better messaging and career exploration platform.


Security


Xgene is very concerned with safeguarding your information. We employ reasonable physical, technological, and administrative security measures and attempt to ensure they are applicable under the circumstances. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.


Transfers Out of the EEA and Privacy Shield


Xgene’ data centers are located in the United States. If you live outside the United States, then by using our services, interacting with our website, or otherwise providing your personal data to us, your personal data will be transferred to and processed in the United States.

If you live within the European Economic Area, Xgene complies with the the EU’s General Data Protection Regulation (“GDPR”) and Swiss data privacy laws regarding the collection, use, and retention of personal information from data subjects who reside in the EU, and which has been adopted by the EEA.

Consistent with the Privacy Shield Principles, if Xgene transfers your personal information to a third party acting as Xgene’ agent on Xgene’ behalf (such as Xgene’ cloud hosting provider located in the United States) then Xgene shall remain liable if its agent processes your personal information in a manner inconsistent with the Privacy Shield Principles, unless Xgene can prove that it is not responsible for the event giving rise to damage.


Business Transfers


Xgene may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.


Phishing


Identity theft and the practice currently known as “phishing” are of great concern to Xgene. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, social insurance number, social security number or any other national identification numbers in a non-secure or unsolicited e-mail or telephone communication.


Controlling Your Privacy


Account Information


You may update your account information by logging into your online account. To delete your account, contact us at eldon.chang@xgenepharm.com. Note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you up to two months.


Profile Information


You can correct information displayed in your profile in the Xgene profile database or choose to remove yourself from the database entirely. To request a change or deletion, email eldon.chang@xgenepharm.com.


Cookies


Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our websites. For further information about cookies and how to manage them, please visit www.alaboutcookies.org. 


Promotional Communications


You may opt out of receiving promotional messages from Company by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.


Disputes Regarding Our Privacy Practices


Except for residents of the European Union and Switzerland, if you have a dispute with relating to our privacy practices, please email us at eldon.chang@xgenepharm.com. Most can be resolved that way.

For European Union and Swiss residents, if you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, we have chosen JAMS Privacy Shield Program to serve as an independent recourse mechanism for dispute resolution arising from collection, use, and retention of personal information transferred from EU member countries and Switzerland to the United States. The services of JAMS Privacy Shield Program are provided at no cost to you.

Further, as explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.


Compliance with Laws and Law Enforcement


Xgene cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Xgene or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.


Contact


Any questions about this Privacy Notice or requests for corrections or deletion of data should be addressed to:

Email: eldon.chang@xgenepharm.com