Privacy Policy

1 Introduction

Complement Therapeutics Limited (referred to as “Complement Therapeutics”, “We, “Our” or “Us” and inclusive of any affiliates or subsidiaries) are committed to protecting the privacy and security of your Personal Data.

This Complement Therapeutics Privacy Notice applies to you if you are:

A service user of this website (https://complementtx.com);
A Complement Therapeutics clinical trial participant;
A healthcare professional conducting a Complement Therapeutics clinical trial;
An employee, contractor, or consultant contracted by Complement Therapeutics;
An employee, contractor, or consultant contracted by Complement Therapeutics’ Service Providers; or,
Any other individual with whom Complement Therapeutics may conduct commercial operations.

We have developed this Privacy Notice to inform you of the data we collect, what we do with your information, what we do to keep it secure as well as the rights and choices you have over your Personal Data. It is important that you read this notice so that you are aware of how and why we are using such information.

2 Definitions

For the purposes of this Complement Therapeutics Privacy Notice:

Complement Therapeutics (referred to as “We”, “Us” or “Our” in this Agreement) refers to Complement Therapeutics Ltd having its registered address at:
4th Floor, Translation And Innovation Hub, 84 Wood Lane, White City, London, United Kingdom, W12 0BZ.

Cookies are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Data Controller, for the purposes of both UK and EU GDPR, refers to Complement Therapeutics as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. For the purpose of both UK and EU GDPR, Complement Therapeutics is the Data Controller.

Data Processor, for the purposes of both UK and EU GDPR, refers to Complement Therapeutics’ Service Providers.

Data Protection Legislation, as defined in the Data Protection Legislation section below.

Personal Data is any information that relates to an identified or identifiable individual.
For the purposes of both UK and EU GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

Service refers to the Website, unless otherwise stated.

Service Provider means any natural or legal person who processes the data on behalf of Complement Therapeutics. It refers to third-party companies or individuals employed by Complement Therapeutics to facilitate the Service, to provide the Service on behalf of Complement Therapeutics, to perform services related to the Service or to assist Complement Therapeutics in analyzing how the Service is used. For the purpose of both UK and EU GDPR, Service Providers are considered Data Processors.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to the Complement Therapeutics website, accessible from https://complementtx.com

You means the individual accessing or using the Service, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under both UK and EU GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

3 Data Protection Legislation

Throughout this document we refer to Data Protection Legislation.

United Kingdom

In the context of the United Kingdom (“UK”), Data Protection Legislation means the United Kingdom General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 (“DPA 2018”), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”), the Data (Use and Access) Act 2025 (“DUAA”), and any legislation implemented in connection with the aforementioned legislation.

European Union (EU) and European Economic Area (EEA)

In the context of the European Union (“EU”) and European Economic Area (“EEA”), Data Protection Legislation means the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”) as well as any local data protection implementation laws. This includes any replacement legislation coming into effect from time to time.

United States

In the context of the United States of America (“US”), Data Protection Legislation refers to any federal, state, sectoral, or case laws and regulations governing the privacy and security of personal data. This includes applicable state privacy legislation, including, but not limited to, the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), as well as other relevant state and federal regulations. This definition also encompasses any legislation implemented under these laws and any replacement or additional legislation enacted from time to time.

Other Jurisdictions

Depending on your jurisdiction, additional Data Protection Legislation may apply. If you have any questions, you can contact our DPO using the details in the Contact Us section below.

Data Controllership

Complement Therapeutics is the Data Controller (‘controller’) for the Personal Data we process, unless otherwise stated.

We have appointed a Data Protection Officer (DPO) to help us monitor internal compliance, inform, and advise on data protection obligations, and act as a point of contact for data subjects and supervisory authorities. For further details on how you can contact our DPO, please see the Contact Us section below.

4 The information we collect

We only collect Personal Data that we know we will genuinely use and in accordance with the Data Protection Legislation and/or legislation related to clinical trials, such as The Medicines for Human Use (Clinical Trials) Regulations 2004, as amended. The type of Personal Data that we will collect on you will depend on whether you are a clinical trial participant, a healthcare professional, an employee, contractor, or consultant, or a user of this website:

Clinical Trial participant (inclusive of any parents, partners, and children)†

Your name*
Your date of birth*
Your age
Your gender
Your contact information (telephone number or email address)*
Where applicable, the name of your legally authorized representative*
Where applicable, the name and contact details of your partner*
Your pseudonymized unique identification number(s)
Your health data
Your genetic data
Your ethnicity

Healthcare professional (HCP)

Your name
Your contact information (telephone number, email address, or mailing address)
Your employment details
Your professional experience
Your research information, including interactions with our research and clinical trials
Where relevant, your pseudonymized unique identification number(s) (e.g., license no.)
Where applicable, your financial information (e.g., bank information)
Where applicable, financial disclosure information regarding you, your spouse, and any adult children

Employees, Contractors, and Consultants of Complement Therapeutics or Complement Therapeutics’ Service Providers

Your name
Where applicable, your date of birth
Your contact information (telephone number, email address, or mailing address)
Your employment details
Your professional experience
Where relevant, your pseudonymized unique identification number(s) (e.g., payroll no.)
Where relevant, your financial information (e.g., bank information)
Where relevant, your Right to Work information (e.g., nationality)
Where relevant, your health data (e.g., sick leave information)

Website User†

Where applicable, your name
Where applicable, your contact information (email address)
Where applicable, your Contact Us form responses
Your Usage Data (e.g., your IP address)
Information relating to Cookies and Tracking Technologies

* This participant identifiable information is collected by Complement Therapeutics’ Research Sites and other vendors, acting on their behalf as Data Processors. This data may be shared with clinicians, health authorities, ethics bodies and other personnel as authorized by Complement Therapeutics, but only where Complement Therapeutics is legally obligated to process this data in accordance with Clinical Trial Regulations and other applicable laws. In certain circumstances, such as where Complement Therapeutics, their Contract Research Organization, and/or Trusted Data Processors inspect Research Sites and their activities, Complement Therapeutics or the relevant parties may have limited, temporary access to your identifiable medical records. However, in general, Complement Therapeutics will not directly receive participant identifiable information and will not instruct their Data Processors to process or share this information other than where the law requires.

† You are under no statutory or contractual requirement or obligation to provide us with your Personal Data; however, we require at least the information above in order for us to deal with you as a Service User in an efficient and effective manner.

5 Cookies, Analytics and Tracking Technologies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. We use both session and persistent Cookies for the purposes set out below:

Strictly Necessary Cookies
Type: Session Cookies
Administered by: Us; Third Parties
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Functionality Cookies
Type: Persistent Cookies
Administered by: Us; Third Parties
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features, or functionality of the Website to see how our users react to them.

Cookie Name	Cookie Description	Cookie Type
__cf_bm; cf_clearance	CloudFlare cookies placed to detect, read, and filter requests from suspected bots.	Strictly Necessary Cookies
player_clearance	Vimeo cookie placed to detect, read, and filter requests from suspected bots.	Functional Cookies
vuid	Vimeo-generated ID used for generating analytics information for the video owner.	Tracking and Performance Cookies
_ga; _ga_[ID]	Google Analytics used to store and count pageviews for analytics purposes.	Tracking and Performance Cookies

We and the third parties we work with use cookies and similar tracking technologies to collect information about your use of the Services, such as your IP address, browser type, browser version, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Services and other websites, provide customer support, troubleshoot issues with and improve the operation of our Website and Services, and better understand your online activity.

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on how Google collects and processes data click here. To opt out of tracking by Google Analytics, click here.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

6 How we use your information

We will only process your Personal Data when the law allows us to do so. We will have provided you with our lawful basis for processing your Personal Data at the point the information was initially collected from you. We will not store, process, or transfer your data unless we have an appropriate lawful reason to do so.

Under Data Protection Legislation, the lawful bases we rely on for processing your information are:

GDPR Article 6(1)(a) – Your consent;*
GDPR Article 6(1)(b) – We have a contractual obligation;
GDPR Article 6(1)(c) – We have a legal obligation;
GDPR, Article 6(1)(d) – In order to protect the vital interests of You or a third party;
GDPR, Article 6(1)(e) – We have a public interest; or,
GDPR, Article 6(1)(f) – We have a legitimate interest.

* Where the lawful basis for processing is Consent, you are able to remove your consent at any time. You can do this by contacting our DPO using the contact details provided in the Contact Us section below.

We may use your information for the following purposes:

Lawful Basis and, where applicable, Special Category Personal Data Condition	Purpose
Our Legitimate Interest in conducting scientific research GDPR, Article 6(1)(f) GDPR, Article 9(2)(j)	Clinical Trial Operations (Legitimate Interest) Where you are a clinical trial participant in a jurisdiction where clinical trials occur on the lawful basis of Legitimate Interest, to collect information from you and process your health information in order to conduct a clinical trial.
Our Legitimate Interest in conducting clinical activities GDPR, Article 6(1)(f)	Clinical (Healthcare Professional Administration) Where you are a Health Care Professional (HCP) involved in the planning, delivery, or oversight of Complement Therapeutics clinical trials, to collect information from you and process your employment information in order to conduct a clinical trial.
Contractual Obligation GDPR, Article 6(1)(b)	Employment Where you are an employee, contractor, or consultant of Complement Therapeutics, to collect information from you and make available our Services to you for the purposes of fulfilling our contractual obligations with you.
Our Legitimate Interest in managing Complement Therapeutics’ affairs GDPR, Article 6(1)(f)	Service Providers (Legitimate Interest) Where you are an employee, contractor, or consultant of Complement Therapeutics’ Service Providers, to collect information from you or your employer and make available our Services to your employer.
Contractual Obligation GDPR, Article 6(1)(b)	Service Providers (Contractual Obligation) Where you are an employee, contractor, or consultant of Complement Therapeutics’ Service Providers, to collect information from you and take payment from you, make a payment to you, give you a refund or request a refund.
Our Legitimate Interest in managing Complement Therapeutics’ affairs GDPR, Article 6(1)(f)	Service Providers (Performance) Where you are an employee, contractor, or consultant of Complement Therapeutics’ Service Providers, to collect information from you or your employer and liaise with your employer about your contact details and/or the nature and performance of your work, as required.
Our Legitimate Interest in providing Services to you GDPR, Article 6(1)(f)	Service Provision To collect information from you and monitor, provide and maintain our Services.
Our Legitimate Interest in providing Services to you GDPR, Article 6(1)(f)	Inquiries To contact you following your inquiry where you have provided your contact information and to reply to any questions, suggestions, issues, or complaints, including any Data Subject Requests, about which you have contacted us.
Our Legitimate Interest in providing a secure platform GDPR, Article 6(1)(f)	Security To collect your Usage Data in order to power our security measures and Services so you can safely access our website and other Services.
Our Legitimate Interest in contacting you about our Services GDPR, Article 6(1)(f)	Service Messages To contact you, where you have provided your contact information, about news and information relating to our Services through Service messages.
Our Legitimate Interest in marketing our Services to you GDPR, Article 6(1)(f)	Direct Marketing (Legitimate Interest) B2B direct marketing to you, where you have provided your contact information, about Services from us where you are classified as a corporate subscriber and/or the ‘soft opt-in’ applies under the UK PECR and/or EU ePrivacy legislation.
Your Consent GDPR, Article 6(1)(a)	Direct Marketing (Consent) B2B direct marketing to you, where you have provided your contact information, about Services from us where you are a sole trader, partnership or otherwise classified as an individual subscriber and/or the ‘soft opt-in’ does not apply under UK PECR and/or EU ePrivacy legislation.
Vital Interest GDPR, Article 6(1)(d) GDPR, Article 9(2)(c)	Vital Interest Monitor your health in order to safeguard and protect you, or to act in your vital interest, or the vital interest of a third party.
Legal Obligation, including, but not limited to, our Legal Obligation to comply with Employment Law GDPR, Article 6(1)(c) GDPR, Article 9(2)(b)	Legal Obligation To comply with our legal obligations, such as retaining any accounting information generated during the course of our interaction for statutory accountancy retention periods.
Our Legitimate Interest in managing any Complement Therapeutics’ legal claims GDPR, Article 6(1)(f) GDPR, Article 9(2)(f)	Legal Claims To respond to and defend against legal claims, where you have provided us with information which may give rise to legal claims.

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 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.

7 Criminal convictions and offences data

Where you are an employee, contractor, or consultant for Complement Therapeutics – or you are a candidate for such a role – and depending on the jurisdiction in which you operate and on the specific role in question, we may collect information about your criminal convictions and offences. We do this to satisfy ourselves that there is nothing in your criminal convictions and offences history which makes you unsuitable for the role. Our roles require a high degree of trust and integrity, and it is therefore best practice to undertake such checks and a pre-requisite in some instances.

We will only collect and use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations, or where we have an overriding legitimate interest to do so, and provided we do so in line with our Data Protection Policy. We have in place appropriate policies and safeguards which we are required by law to maintain when processing such data.

8 Automated technologies and AI use

As part of our ongoing efforts to improve the efficiency and quality of our research and clinical trial activities, we may use artificial intelligence (AI) tools (“AI tools”) to support data analysis, communication, and system functionality.

Where AI tools are used, we take steps to ensure that personal data is minimised, protected, and processed in accordance with applicable data protection law, and we do not intentionally submit personal data to publicly available AI models without appropriate safeguards.

Our use of AI tools for processing your personal data is carried out on the basis of our Legitimate Interests to conduct clinical research. We balance our interests against your data protection rights and apply appropriate safeguards to protect your personal data.

If you have any questions or concerns about this processing, please contact our Data Protection Officer on the contact email address set out in the Contact Us section.

9 Who we might share your information with

We may share your personal data with other organizations in the following circumstances:

From time to time, we may need to share your Personal Data with our affiliates and/or strategic clinical trial partners;
If the law or a public authority says we must share the Personal Data;
If we need to share Personal Data in order to establish, exercise or defend our legal rights – this includes providing Personal Data to others for the purposes of detecting and preventing fraud; or
From time to time, employ the services of other parties for dealing with certain processes necessary for the operation of our services.

We use Service Providers (“Data Processors”) who are third parties who provide elements of services for us. Examples of these Data Processors include, but are not limited to:

Our Contract Research Organizations (CRO);
Our Clinical Trial Data Processors,
Our IT Service Providers, such as Microsoft Corporation.

We have Data Processor Agreements in place with our data processors. This means that they cannot do anything with your Personal Data unless we have instructed them to do it. They will not share your Personal Data with any organization apart from us or further sub-processors who must comply with our Data Processor Agreement. They will hold your Personal Data securely and retain it for the period we instruct.

10 How long we keep your information for

We retain a record of your Personal Data in order to provide you with a high quality and consistent service. We will always retain your Personal Data in accordance with the Data Protection Legislation. Where EU GDPR and UK GDPR apply, Complement Therapeutics has a Retention Schedule in place which outlines how long Complement Therapeutics will retain different categories of Personal Data. Complement Therapeutics considers the retention period to begin from the point at which Complement Therapeutics last contacted you or otherwise reviewed your record to determine whether it was still active, or from the end of the applicable study, contract, or legal obligation, whichever is later, unless otherwise required by law. As such, where EU GDPR and UK GDPR apply, unless otherwise required by law, your data will be retained for the period specified in the summarized table below and then securely deleted in accordance with our internal policies and procedures.

Purpose	Retention Period
Processing data in relation to You as a clinical trial participant	Up to 30 years
Processing data in relation to You as a Health Care Professional (HCP) involved in the planning, delivery, or oversight of a Complement Therapeutics’ clinical trial	Up to 30 years
Processing data in relation to You as an employee, contractor, or consultant contracted by Complement Therapeutics	7 years following the termination of your employment
Processing data in relation to You as an employee, contractor, or consultant contracted by Complement Therapeutics’ Service Providers	7 years following the termination of your employment
Processing data in relation to You as a service user of this website	1 year
Processing data in relation to You as any other individual with whom Complement Therapeutics may conduct commercial operations	7 years

11 International Transfers

Your Personal Data is processed at Complement Therapeutics’ operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. In particular, when Complement Therapeutics shares clinical trials data with Trusted Data Processors, your Personal Data would be stored and processed within third countries. Where you are based in the EU, EEA, or UK, Complement Therapeutics will ensure that:

any Data Controller receiving your Personal Data has entered into an agreement with Complement Therapeutics which contains standard data protection clauses as required by UK and/or EU GDPR or there is an alternative appropriate safeguard in place governing the transfer; and,
any Data Processor receiving your Personal Data has entered into an agreement with Complement Therapeutics which contains the required Data Processor clauses as well as standard data protection clauses as required by UK and/or EU GDPR or there is an alternative appropriate safeguard in place governing the transfer.

Where you are based in the UK or EU and we were required to transfer your Personal Data out of the UK or EU to countries not deemed by the ICO or European Commission (as relevant) to provide an adequate level of Personal Data protection, the transfer will be based on safeguards that allow us to conduct the transfer in accordance with the Data Protection Legislation, such as the specific contracts containing standard data protection clauses approved by the ICO or European Commission (as relevant) providing adequate protection of Personal Data. You can obtain a copy of this documentation by contacting our DPO as identified in the Contact Us section below.

12 Security

Data security is of great importance to Complement Therapeutics. We have put in place appropriate technical and organizational measures to prevent your Personal Data from being accidently lost, used, or accessed in an unauthorized way, altered, or disclosed.

We take security measures to protect your information including:

Limiting access to our buildings and resources to only those that we have determined are entitled to be there (by use of passes, key card access and other related technologies);
Managing a data security breach reporting and notification system which allows us to monitor and communicate information on data breaches with you or with the applicable regulator when required to do so by law;
Implementing access controls to our information technology; and,
Deploying appropriate procedures and technical security measures (including strict encryption, anonymization and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps, offices, and stores.

13 How we keep you updated on our products and services

Where you are a clinical trial participant or a Health Care Professional involved in the planning, delivery, or oversight of a Complement Therapeutics clinical trial, we will contact you through our Contracted Research Organization (CRO) where it is necessary to do so.

Where you are an employee, contractor, or consultant of Complement Therapeutics, we will contact you through existing Complement Therapeutics communication channels, including email, where it is appropriate to do so.

Where you are an employee, contractor, or consultant of Complement Therapeutics’ Service Providers, a user of this website who has provided us with your contact information, or any other business contact, we will send you relevant news about our services in a number of ways including by email, but only if we have a Legitimate Interest to do so. Where we do not have a Legitimate Interest, we will not send you marketing communications unless we have asked for, and gained, your consent.

We make every effort to ensure that we only send such communications to those acting in a business capacity and do not send such materials to consumers via personal email addresses if it is clear they are not acting in such a capacity or have not otherwise provided their consent.

All email communications will have an option to unsubscribe and so if you wish to amend your marketing preferences, you can do so by following the link in the email and updating your preferences. Alternatively, you can contact our DPO using the contact details provided in the Contact Us section below.

14 Giving your reviews and sharing your thoughts

When using our website and other Services, you may be able to share information through social networks like LinkedIn and X. For example, when you ‘like’, ‘share’ or review our Services. When doing this, your Personal Data may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts so that you are comfortable with how your information is used and shared on them.

15 Third Party websites and links

Our Website may contain links to other sites operated by third parties, such as LinkedIn, X, or Vimeo. Complement Therapeutics does not control such other sites and is not responsible for their content, their privacy policies, or their use of personal information. Complement Therapeutics’ inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed through the Services. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties.

16 What happens if our business changes hands?

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use that data only for the purposes for which it was originally collected by us.

17 Children’s privacy

Notwithstanding where we may process the Personal Data of the children of clinical trial participants in order to meet our obligations under clinical trial legislation, such as in the event that a participant or their partner becomes pregnant during the course of a clinical trial, we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a minor child who has provided us with personal information, you may contact us using the information below to request it be deleted.

18 Your rights over your information

European Union, European Economic Area, and the United Kingdom

Where EU GDPR and UK GDPR apply, you have certain following rights over your Personal Data. For your protection, and to protect the privacy of others, we may need to verify your identity before completing what you have asked us to do. If you would like to exercise these rights, or if you would like more information about your rights or have any concerns about how we process your personal information, please Contact Us as set out below.

18.1.1 The right to be informed about our collection and use of personal data;

You have the right to be informed about the collection and use of your personal data. We ensure we do this with our internal and external Privacy Notices (including this document). These are regularly reviewed and updated to ensure these are accurate and reflect our data processing activities.

18.1.2 Right to Access Your Personal Data

You have the right to access the Personal Data that we hold about you in many circumstances, by making a request. This is sometimes termed a ‘Data Subject Access Request’. If we agree that we are obliged to provide Personal Data to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 1 month from when your identity has been confirmed. If your request is particularly complex, we may extend this response window to a total of 3 months. We would ask for proof of identity and sufficient information about your interactions with us that we can locate your Personal Data.

18.1.3 Right to Rectify Your Personal Data

If any of the Personal Data we hold about you is inaccurate, incomplete, or out of date, you may ask us to correct it. If we shared your Personal Data with others, we will tell them about the correction where possible.

18.1.4 Right to Erasure

You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances. For instance, the right to erasure does not apply where we have a legal obligation to retain your Personal Data. If we shared your data with others, we will alert them to the need for erasure where possible.

18.1.5 Right to Restrict Processing

You have the right to ask us to restrict the processing of your personal data. For example, this may be because you have issues with the accuracy of the data we hold or the way we have processed your data. The right is not absolute and only applies in certain circumstances. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible.

18.1.6 Right to Portability

The right to portability gives you the right to receive personal data you have provided to a controller in a structured, commonly used, and machine-readable format, where the lawful basis for processing relies upon consent or a contract entered into with you. It also gives them you the right to request that a controller transmits this data directly to another controller.

18.1.7 Right to Object

You have the right to object to our processing of some or all of the personal data that we hold about you. This is an absolute right when we use your data for direct marketing but may not apply in other circumstances where we have a compelling reason to do so, e.g., a legal obligation.

18.1.8 Rights Related to Automated Decision-Making

You have the right to object to our processing where a decision is made about you solely based upon automated processed and which has significant or legal effects. Complement Therapeutics does not intend to conduct any automated decision-making for your Personal Data. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have otherwise notified you.

18.1.9 Right to withdraw consent

If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.

18.1.10 Right to lodge a complaint with the data protection authority

If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

18.1.11 For more information about your privacy rights

If you are in the UK, you have the right to lodge a complaint directly with us at any time, or you may lodge a complaint with the Information Commissioner’s Office (ICO) (https://ico.org.uk/for-the-public), the UK supervisory authority for data protection.

If you are in the EU or EEA, you also have the right to lodge a complaint at any time with the relevant supervisory authority responsible for data protection. For a list of the relevant supervisory authorities, please see https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Depending on your jurisdiction, it is possible that a different regulator or supervisory authority may govern the processing of Personal Data. If you have any questions about which supervisory authority applies in your jurisdiction, please Contact Us as set out below.

California Data Protection Legislation

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”) requires that we provide you with a privacy policy of our online and offline information practices and your rights under this law regarding your personal information.

We currently collect, share, disclose, and use your personal information. In the 12 months prior to the last updated date of this Privacy Notice, we have collected, shared, disclosed the personal information set out in this Privacy Notice. We may collect personal information directly from California and other US state residents, credit reporting agencies, and/or our third-party service providers. We do not collect all categories of personal information from each source.

18.1.12 California Resident Rights

California residents are afforded the following rights:

to delete your personal information, unless we:
can prove this to be impossible;
it involves disproportionate effort; or
it is reasonably necessary for us to maintain records in order to fulfil the transaction(s) for which the personal information was collected;
to correct inaccurate personal information held about you;
to know what personal information is sold or shared and to whom (this right is fulfilled with the information provided within this Notice);
to request specific pieces of information from us;
to opt out of the sale or sharing of your personal information;
to limit use and disclosure of sensitive personal data; and,
to no retaliation following opt-out or exercise of other rights.

If you would like to contact us regarding this right, please Contact Us as set out below. Please note that we may need to verify your identity before processing your request. Rights requests shall be reviewed to see if an exemption allows us to retain the information. We may deny your deletion request if an exemption applies and/or if retaining the information is necessary for us or our Service Provider(s), for example to detect fraudulent activity or comply with a legal obligation. We will delete, de-identify or limit the scope of personal information not subject to an exemption from our records and will direct our Service Providers to take similar action.

United States – Other Data Protection Legislation

Other US Data Protection Legislation

If you are a US resident, we process your personal data in accordance with applicable US state data privacy laws, including the CCPA/CPRA described above. This section of our Privacy Notice contains information required by other US state data privacy laws and supplements the above section on CCPA/CPRA.

Several US states have enacted comprehensive privacy statutes, including but not limited to Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. These laws include provisions aimed at safeguarding consumer rights and outlining business obligations. If you have relevant rights under these laws, you can exercise them by contacting us using the details provided in the Contact Us section as set out below.

Our practices are designed to adhere to the highest standards set forth by these laws, ensuring that we respect the privacy rights of all individuals. As the US privacy laws continue to evolve, we will monitor these changes, adjust our privacy practices, and update our Privacy Notice(s), accordingly.

18.1.13 We Do Not Sell Your Personal Information

You have the right to know whether your personal information is being sold. Your personal information is “sold” when it is provided to a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as set forth in the CCPA or other US state data privacy laws.

Please note a “sale” does not include when we disclose your personal information at your direction, or when otherwise permitted under law.

18.1.14 We May Share Your Personal Information

We may “share” your personal data, as defined under California and other applicable US state laws, for personalised advertising purposes and/or for any other purposes outlined in this Privacy Notice.

18.1.15 Do Not Track

Due to varying practices among browser providers and the lack of a market standard, we do not respond to Do Not Track signals at this time.

18.1.16 Non-Discrimination

US state privacy laws prohibit businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying goods or services, providing a different level or quality of service, or charging different prices.

The CCPA permits businesses to provide differing levels or quality or different prices where the business can demonstrate that the difference is reasonably related to the value to the business of the consumer’s personal information.

Other Data Protection Legislation

If you are located in another jurisdiction outside of the EU, EEA, UK, and US, you may have data protection rights available to you under the applicable Data Protection Legislation of your jurisdiction, such as the right of access, rectification, and/or erasure. If you have relevant rights under these laws, you can exercise them by contacting us using the details provided in the Contact Us section as set out below.

19 Contact Us

If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this Privacy Notice or the way your Personal Data is processed, please contact us by one of the following means:

Complement Therapeutics Limited Data Protection Officer

By email: dpo@complementtx.com

20 Changes to Our Privacy Notice

Thank you for taking the time to read our Privacy Notice.

We may change this Privacy Notice from time to time (for example, if the law changes). We recommend that you check this Privacy Notice regularly to keep up-to-date.