LianBio Privacy Notice

Last Updated: September 2023

Welcome to the Privacy Notice (“Notice”) of LianBio, as well as its affiliates and subsidiaries that link to this Notice (collectively, referred to as “LianBio”, “we,” “our,” “us,” or “Controller”).  This Notice describes our general practices regarding how we collect, use and disclose the information of visitors to our websites and online services that link to this Notice ("Sites"), caregivers, health care professionals, vendors, business partners, and investors.  We refer collectively to our Sites and offerings herein as the "Services."

This Notice explains our general practices for processing your information, including what information we collect when you use the Services, how we use and share that data, and your choices concerning our data practices.  By engaging with the Services, you agree to the practices described in this Notice. If you do not agree to this Notice, please do not access or use the Services.

This Notice contains the following sections:

1. THE INFORMATION WE COLLECT AND HOW WE USE IT 

1.1 Site Visitors

1.1.1 Information We Collect from Site Visitors

When you access our Sites, we collect the following types of information from and about you.

Information You Provide Us. We collect information that visitors to the Sites send to us electronically, for example when completing any “free text” boxes in our forms (such as on our “Contact” page), requesting information, or subscribing to email lists. The types of information we collect through these methods depend on the nature of your inquiry, but typically include, and are not limited to, contact information (such as your name, postal address, e-mail address, telephone number), date of birth, government-issued IDs, professional credentials, experiences, skills, preferences, hobbies and interests, and other information you provide us. If you register on our Sites, we will also collect information such as a username and password.

Information We Automatically Collect.  As discussed further below, we and our third-party service providers, which include ad networks and analytics companies including Adobe Analytics, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Sites. Through these technologies, we may collect and analyze information including but not limited to: IP address; browser type; operating system; domain names; access times and duration of access; referring or exit pages; page views; unique device identifiers; and the type of device that you use. We use this information (including the information collected by our third-party service providers) for analytics (including to determine which portions of the Sites are used most frequently and what our users like/do not like), to assist in determining relevant advertising (both on and off the Sites), to evaluate the success of our advertising campaigns, to tailor content to your interests, and as otherwise described in this Notice.

1.1.2 How We Use Information Collected from Site Visitors

As necessary for certain legitimate business interests, which include the following:

  • To respond to your inquiries and fulfill your requests;
  • To authenticate users and provide access to the Sites;
  • To recruit and/or consider you for employment;
  • Where you have consented to receive direct marketing communications, or where you have previously purchased similar services or products from us, to send you marketing communications (in accordance with applicable local legal requirements) about products, services, and initiatives that we think may be of interest to you;
  • For regulatory reporting, such as adverse event or pharmaceutical transparency reporting;
  • To send you transactional and administrative messages about our Services and your interactions with us;
  • To prevent fraud or criminal activity, misuse of our Services, and ensure the security of our IT systems, architecture and networks; and
  • To (a) comply in good faith with legal obligations and legal processes; (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our legal terms; (d) protect our operations or those of any of our affiliates; (e) protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain, as required or permitted by the law.

Note about cookies and tracking technologies. As noted above in the “Information We Automatically Collect” section, our Sites use cookies and similar technologies to operate and administer our Sites, analyze usage data, advertise our services, and make it easier for you to use the Sites during future visits.  You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to disable cookies if you prefer. If you disable cookies, you may not be able to use all parts of the Services.

We may use third party partners (e.g., ad networks and ad servers) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Sites. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative's Consumer Opt-Out Link and/or the Digital Advertising Alliance's Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. Please note that we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI's and DAA's websites, accessible by the above links.

Please note that the Sites currently do not respond to “Do Not Track” (“DNT”) signals and operate as described in this Notice whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Notice to describe how we do so.

Links to Other Websites.  Our Sites may contain links to other websites not operated or controlled by us (“Third Party Websites”). The information that you share with Third Party Websites will be governed by the specific privacy notices and terms of service of the Third Party Websites and not by this Notice. We do not own, control or operate such Third Party Websites, and we are not responsible for the privacy notices or practices of such Third Party Websites. By providing these links, we do not imply that we endorse or have reviewed these Third Party Websites. We encourage you to read the privacy notices of such Third-Party Websites before disclosing information on Third Party Websites.

1.2 Key Opinion Leaders, Researchers, and Healthcare Professionals.

1.2.1 Information We Collect from Healthcare Professionals, Researchers, and Key Opinion Leaders

We collect information about you as a Healthcare Professional (“HCPs”), Researcher, and/or Key Opinion Leader (“KOLs”) through interactions we have with you, from patient advocacy groups, study sites, publicly available sources, and professional networking platforms and social media pages (e.g. LinkedIn). If you attend scientific or educational meetings, conferences, and workshops we sponsor, we also receive information regarding your attendance from the organizations that conduct those events in accordance with the sharing permissions granted to such organizations.

How We Use Information from KOLs, Researchers, and HCPs

Where necessary for LianBio’s legitimate interests, as listed below, and where our interests are not overridden by your data protection rights, we may use information collected from KOLs and HCPs to:

  • manage and administer our relationship with you and to respond to your requests;
  • record, investigate and respond to complaints;
  • manage and follow up on adverse events reports.

Where necessary to comply with a legal obligation, including sharing your information in order to respond to requests from law enforcement authorities.

With your consent, we may use your information to:

  • provide you with information about our activities or tailored information about a program that you have signed up to;
  • understand our stakeholders’ needs and market trends, so that we can improve our products and services (where such communication includes marketing); and
  • seek your views on our products and services (where such communication includes marketing)

1.3 Vendors, Business Partners, and Investors

1.3.1 information We Collect from Vendors, Business Partners, and Investors

We collect information about employees, contractors and representatives of our vendors, business partners, and investors when we use or contemplate using their products/services or otherwise working with them. Such information may include name, job title, contact information, and transactional history.

1.3.2 How We Use Information from Vendors, Business Partners, and Investors

Where necessary for LianBio’s legitimate interests, and where our interests are not overridden by relevant data protection rights, we may use this information to perform diligence on vendor and partner products and services, for billing and administrative purposes, to provide information relevant to LianBio, to manage our relationship, and for record keeping purposes.

1.4  Research Participants

If you participate in a LianBio clinical research project (“Research”), please note that you will be provided with any relevant informed consent forms, privacy notices, and/or trial documents in relation to the collection, use, and transfer of your information for the Research purpose at the time of such Research.  Those documents, and not this Notice, will govern the collection of information through our Research.

2.  DISCLOSURE OF INFORMATION

With your consent, we may share or disclose your information at your direction, such as when you specifically authorize a third-party to access information that we maintain about you.

Where necessary for our legitimate interests and where our interests are not overridden by your data protection rights, we may, from time to time, disclose your information amongst our affiliates and to third parties for the purposes referred to above including:

  • manage and administer our relationship with you and respond to your requests;
  • protect our operations;
  • protect our rights, privacy, safety or property, you or others.

There are certain circumstances in which we may share your information with third parties without further notice to you, unless required by applicable law, as set forth below. We will require the recipients to use your information only for appropriate purposes and take appropriate measures to protect your personal information.

  • Service Providers: We disclose your information to other entities providing services on our behalf, including providers of administrative services such as email communication (including investment information you request through the Sites), event organization, for processing and mailing purposes, customer relationship management, support services, and other business operations such as data storage, data analytics providers (in connection to Site analytics), distributors, IT and data security, legal services, etc. Pursuant to our instructions, these parties will access, process or store information only in the course of performing their duties to us.
  • Business partners and research organizations who collaborate with us in relation to our products and services, such as researchers with who we partner, companies with which we co-develop an investigational drug, etc.
  • Business Transfers or Acquisitions: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your information may be transferred to a successor or affiliate as part of that transaction along with other assets, to potential acquirers, financiers, and professional advisers in connection with a proposed sale, assignment or other transfer.
  • Legal Requirements: If required to do so by law or in response to a government or law enforcement agency, or in the good faith belief that such action is necessary, including but not limited to (a) comply with a legal obligation, (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of you, us, or the public, or (d) protect against legal liability.

3. DATA RETENTION

We will keep your information for as long as reasonably necessary for the purposes described in this Notice. For instance, for certain processing we will retain your information for so long as we have a legitimate business need to do so, or for certain information we will retain the processing for such period as is required by law (e.g. for legal, tax, accounting or other purposes).

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

Anonymized information. In accordance with applicable legal requirements, we may anonymize information collected from and about you so that it can no longer be linked to you or your device. Information that has been anonymized in such a way is no longer subject to this Notice and can be used and shared by us in our discretion, and maintained indefinitely.

4. YOUR RIGHTS AND CHOICES

Your local laws may permit you to:

  • request access to and/or a copy of certain information we hold about you
  • object to the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
  • request that we update or rectify information which is out of date or incorrect
  • request that we delete certain information which we are holding about you
  • oppose, cancel, or restrict the way that we process and disclose certain information
  • receive and transfer your information to a third-party provider of services
  • withdraw your consent for the processing of your information, which will not affect the lawfulness of processing prior to the withdrawal

You may update your information and your preferences provided through the Sites. Different programs and services may offer different phone numbers, links or preference managers that allow you to inform us of your updates and choices, including opting out of particular communications. These contact options are typically available on the Sites, but you may always contact us for assistance at privacy@lianbio.com if you have any difficulty finding these tools or otherwise updating or deleting your information or preferences.

We will consider all requests and provide our response within the time period stated by applicable law. Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. If we are unable to comply with your request in full or part, we will confirm this with you and the reasoning behind our position.  Depending on your jurisdiction of residence, you may have the ability to appeal our decision.

Please note that in certain circumstances we will need to provide you with certain information for us to comply with legal obligations or to administer our relationship with you. We will inform you where such information is required and the consequences of failing to provide such information (which may include an inability for you to create an account on our Sites).

We may request you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law. If you, or an authorized agent of yours, would like further information in relation to your legal rights under applicable law, or would like to exercise those rights, please contact us using the information in the “Contact Us” section below at any time.

5. INTERNATIONAL USERS

Our Services and servers are currently based in the United States and China, among other global jurisdictions, meaning that your information will be processed by us in such locations, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using the Services, you hereby expressly agree to the transfer of all such information to these jurisdictions, and to the processing of that information as described in this Notice.

For residents of Singapore, please visit SG Supplemental Privacy Notice for more information about how LianBio uses your information.

6. UNITED STATES PRIVACY DISCLOSURE

Please note that we do not currently meet the threshold applicability requirements of U.S. state privacy laws, including the California Consumer Privacy Act (“CCPA”). If we meet those thresholds in the future, we will update this Notice to include applicable disclosures related thereto.

7. INFORMATION FROM MINORS

In general, our Services are intended for general audiences and not for children. No information should be submitted to LianBio by visitors who are less than 14 years old. If we become aware that we have collected such information without legally valid parental consent from minors under an age where such consent is required pursuant to applicable law, we will take reasonable steps to delete it as soon as possible.

8. CHANGES TO THIS NOTICE

The Services, our Sites, and our business may change from time to time. As a result, we may change this Notice at any time and when we do, we will post an updated version on this page and change the Last Updated date above, unless another type of notice is required by the applicable law. You should consult this Notice regularly for any changes. By continuing to use the Services or Sites, or providing us with information after we have posted an updated Notice, or notified you if applicable, you agree to the revised Notice and practices described in it.

9. DATA SECURITY

We have implemented a variety of technological and organizational procedures and measures to protect your information. However, please note that we cannot guarantee personal information is absolutely secure. We recommend that you take any available precautions or special care to protect the information you transmit, share, send, upload, or submit on the Sites. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us by contacting us at privacy@lianbio.com.

10. CONTACT US

Please feel free to contact us if you have any questions about our Notice or our information practices.

You may contact us as follows: You may send an email to privacy@lianbio.com or send mail to:

Attn: Legal Department
c/o LianBio (New Jersey Office)
103 Carnegie Center Drive, Suite 309, Princeton, NJ 08540
c/o LianBio (Shanghai Office)
16F, 5 Corporate Avenue, No.150 Hubin Rd, Huangpu District, Shanghai