Ascending as a new biopharmaceutical force

Privacy Notice

Introduction

At Ascendis Pharma A/S (“Ascendis Pharma”), we are working to build a leading, fully integrated biopharmaceutical company that provides meaningful improvement in patients’ lives. For more information about Ascendis Pharma, please visit our website – ascendispharma.com.

Ascendis Pharma respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights within the below-mentioned areas:

 1. Website
            1.1 General Contact Information
            1.2  Investors & News
            1.3  Use of this Website by Minors
 2. Clinical Trials
 3. Contract & Vendor Management
 4. Healthcare Professionals & Other Stakeholders
 5. Job Applicant

If you have any questions or concerns about our use of your personal information or would like to exercise any of your rights — including object to the processing of your personal information in the way that we describe in this notice – please contact us. More information can be found at the end of this notice.

Data controller is Ascendis Pharma A/S, Tuborg Boulevard 12, 2900 Hellerup, Denmark, attn. DataPrivacy@ascendispharma.com.

General Information

Who does Ascendis Pharma share my Personal Information with?
We disclose your personal information to the following recipients:

  • Our group companies, third party services providers and partners, who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. An overview of where we hold offices is available here https://ascendispharma.com/about-us/company-profile/.
  • Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
  • Potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice.
  • Any other person with your consent to the disclosure.

We require all third parties processing personal information on our behalf (data processors) to have appropriate technical and operational security measures in place to protect your personal information, in line with applicable data privacy legislation. We further require that they do not share your personal information with any third parties without our explicit consent and without guaranteeing adequate security standards and that they will hold it securely and retain it for the period we instruct.

Legal basis for processing Personal Information
Our legal basis for collecting and using the personal information described above is our legitimate interest in maintaining a relationship with you. In certain situations, we also ask for your consent to process your personal information, and for clinical trials we also process your personal information for scientific research purposes and in order to live up to a legal obligation.

If you have any queries about the legal basis, please contact us by using the contact details provided in the How to Contact Us section heading below.

How does Ascendis Pharma keep my Personal Information secure?
Ascendis Pharma use appropriate measures to protect your personal information that we collect and process.

Ascendis Pharma takes appropriate technical and organizational measures to ensure that all personal information is kept secure, including security measures to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

Ascendis Pharma limits access to your personal information to those who have a genuine business need. Those processing your personal information will do so only in an authorized manner and they are subject to confidentiality.

Ascendis Pharma also has procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where legally required to do so.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through any online means, therefore any transmission remains at your own risk.

International data transfers
Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

The servers that we use to host your personal information are located in Denmark and the US – and our group companies and third party service providers and partners operate globally. This means that when we collect your personal information, we may process it in any of these countries.

However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Privacy Statement. These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with EU data protection laws.

Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

Data retention
We retain collected personal information where we have an ongoing legitimate business need to do so (e.g., to provide you with a service you have requested).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (e.g., because your personal information has been stored in back-up archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your data protection rights
By law, in some instances you have the right to:

Request information about whether we process your personal information, and, if so, which information and why we are processing it.

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of your personal information and to check that we are lawfully processing it. If you wish to request access to this information, please complete the Request Form.

Request correction of your personal information. This enables you to have any incomplete or inaccurate information corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove your personal information 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 information where you have exercised your right to object to processing (see below).

Object to processing of your personal information 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.

Object to automated decision-making, including profiling. This enables you to object to being subject to a decision based on automated processing.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information, e.g., if you want us to establish its accuracy or the reason for processing it.

Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to receive your personal information in an electronically useable format and to transfer your data to another party in an electronically useable format.

Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries are available here – link.)

You can exercise your data protection rights, as mentioned above, by contacting us using the contact details provided under the How To Contact Us section below.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

We respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

How to Contact Us
If you have any questions or concerns about our use of your personal information, please contact: Ascendis Pharma A/S, Tuborg Boulevard 12, 2900 Hellerup attn.:
DataPrivacy@ascendispharma.com.

1. Website

When using our website, you have the option to provide your personal information for certain requests. Please click on your area of interest and learn more:

1.1. General Contact Information

On the Contact Us section you can see the contact information for all our offices, and you are also able to contact us by sending inquiries to info@ascendispharma.com.

Except where specifically retained, the normal practice is to delete these questions save for the normal back-up of the system.

It is also possible to contact our Medical Affairs team on MedicalAffairs@ascendispharma.com.

Emails received by the Medical Affairs team will be circulated to the appropriate people within Ascendis Pharma with the expertise to address the questions asked. The questions may be retained by Ascendis Pharma if they are relevant for present or future activities of Ascendis Pharma or where there is a legal requirement to retain such questions.

What Personal Information does Ascendis Pharma collect and why?

  • Email and the personal information you provide in your email.

We process this information for the following purposes:

  • To review, assess and answer your question(s).

1.2. Investors & News

The Investor Contact section (IR contact) provides you with a form inviting you to send any investor relations requests.

The recipient of this form is the Ascendis Pharma CFO, who will respond and, if relevant, involve other employees within Ascendis Pharma.

Except where specifically retained, and if necessary for present or future activities of Ascendis Pharma, the normal practice is to delete the form and any related personal information save for the normal back-up of the system.

What Personal Information does Ascendis Pharma collect and why?

  • Depending on the fields you fill in, we may collect: first and last name, email, title, company, investor type, country, workplace, fax, home phone, and comments/questions.
  • News alert: email.

We process this information for the following purposes:

  • Managing our relationship with you by answering your request.
  • Providing you with the relevant news about Ascendis Pharma.

When signing up to automatically receive Ascendis Pharma financial information by use of the Email Alerts section your email will be sent to West LLC that manages all news for Ascendis Pharma.

1.3. Use of this Website by Minors

We do not intend for our websites to be used by anyone under the age of 18.

2. Clinical Trials

At Ascendis Pharma we conduct clinical trials and the protection of personal information is of high importance to us.

In our Subject Information and Consent Form we provide persons participating in our clinical trials with relevant information about our use and processing of their personal information.

Such personal information will be kept in accordance with regulatory requirements for clinical trials, i.e., up to 2 years after the last marketing application which may happen for more than 25 years from collection of such personal information.

What Personal Information does Ascendis Pharma collect and why?
The personal information collected depends on the specific clinical trial, but may include:

  • Ordinary personal information such as your sex, date of birth, body weight and height.
  • Special categories of personal information: your race and ethnicity, your medical data, including your medical history, scans, blood samples, biopsies and your health status and information about your use of the trial medicine, the effect it has on you, and its potential side effects etc.

We process this information for the following purposes:

  • The personal information is collected and processed to support marketing authorization applications.

Ascendis Pharma will only process your personal information in a pseudonymous form. This means that a unique trial identification number will be assigned to you by the study doctor and all personal information shared with Ascendis Pharma will only be linked to this unique trial identification number. Ascendis Pharma will not know your name.

3. Contract & Vendor Management

At Ascendis Pharma we collaborate with third party providers and partners.

Any personal information collected about the employees of these companies will be retained for as long as we have a contractual relationship with their employer and for up to an additional 30 years to fulfil legal requirements, such as bookkeeping, GxP documentation, etc.

What Personal Information does Ascendis Pharma collect and why?
Depending on the interaction we have with you or your employer, we may collect and process the following categories of personal information:

  • Work contact details (such as name, work mobile phone, job title).
  • Contract terms and signature.
  • Billing details and payments.
  • Information about ordering and performance of services.
  • Work product.
  • CVs and other qualification records (only applicable to some).
  • Training documentations (primarily GxP related and only applicable to some).
  • Relation management information.

We process this information for the following purposes:

  • The continuous business relationship between Ascendis Pharma and you or your employer.
  • Compliance with security, safety and product quality requirements.

4. Healthcare Professionals & Other Stakeholders

At Ascendis Pharma we collaborate and interact with Healthcare Professionals and other stakeholders, such as payors and other business partners, to advance our business objectives and gain valuable insights.

What Personal Information does Ascendis Pharma collect and why?

  • Personal information such as your name, age, gender and contact details.
  • Professional information such as your place of practice, job title, the medical field in which you are active, your professional qualifications and scientific activities (such as previous clinical trial experience, and participation in past or pending research studies with Ascendis Pharma and other companies), publication of academic or scientific research and articles, and membership in associations and boards, etc.
  • Information on interactions with Ascendis Pharma, such as what kind of meetings we have held, topics discussed, your knowledge of and questions you have had on our business and products, what kind of material we have displayed to you and any feedback that you have provided, as well as your opinions and routines on prescribing, routines regarding your patients and diagnosis, and similar information.
  • Transfer of value.

We process this information for the following purposes:

  • Managing our relationship with you, also to plan potential collaboration, contact, visits, follow-ups and meetings.
  • To help evaluate the information we provide to you and ensure that it is relevant given your expertise, interests and preferences.
  • To understand your scientific-therapeutic approach and satisfaction with Ascendis Pharma.

We collect information about you from a variety of sources, including directly from you and from:

  • Documents or forms that you provide to participate in Ascendis Pharma-sponsored or -supported initiatives, such as Ascendis Pharma-sponsored clinical research and development activities, or in other contexts.
  • Publicly available sources.
  • CVs.
  • IQVIA OneKey (personal information is continuously uploaded directly to our CRM platform from IQVIA’s own database).
  • Online and other databases and websites, which may be managed by third parties on our behalf.

5. Job Applicant

Ascendis Pharma uses the job site Workable, an online application provided by Workable Software Limited, USA, to assist with our recruitment process.

Where you apply for a job opening through a third party job portal, this portal may collect your consent, which is freely given by you during the application process, to disclose your personal information to the job portal owner and Ascendis Pharma.

You do not have to provide the requested information, but it might affect your application if you do not.

What Personal Information does Ascendis Pharma collect and why?
Personal Information Provided by You
We may collect personal information from you at the application stage, when shortlisting applications for an interview, during the interview and the assessment of your profile for the position, and when making a conditional and/or final employment offer. We may perform pre-employment background and reference checks with your permission and may also perform sanctions screening. All checks/screenings are carried out in a fair and consistent manner and will be limited to information that is directly relevant to the position being applied for and in pursuance of our legitimate business interests.

Specifically, we may collect the following information:

  • Personal information, including name, contact details, and photo, if provided by you.
  • Previous experience and employment entitlements, education, qualifications, CV and answers to questions relevant to the position you have applied for.
  • Information provided when completing tests or profile questionnaires and/or attending an interview.
  • Proof of your identity and qualifications, criminal records if relevant, referrals and health information where legally obligated to collect it.
  • Details of your visits to Workable’s Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Workable’s Website and the resources that you access.
  • Application history for jobs at Ascendis Pharma.

Personal information about your physical or mental health, alleged commission or conviction of criminal offences, and trade union membership are considered “sensitive” personal data under applicable data privacy laws. We will only process such personal information if you have either given your explicit consent, we are legally required or allowed to collect and process it, or you have deliberately made it public. We will only request such sensitive personal information that is necessary, proportionate and in pursuance of our legitimate business interests. By providing any sensitive personal information you explicitly agree that we may collect and use it in accordance with this Privacy Statement.

Personal Information from Other Sources
Workable provides Ascendis Pharma with the facility to link the personal information you provide to Ascendis Pharma, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

Workable’s technology allows Ascendis Pharma to search various databases – some publicly available and others not, which may include your personal information (including your CV), to find possible candidates to fill job openings. Where we find you in this way, we will obtain your personal information from these sources.

Ascendis Pharma may also receive your personal information from a third party who recommends you as a candidate for a specific job opening or for our business more generally.

Where you have applied for a job opening through a third party job portal, and where you have consented to this disclosure, Ascendis Pharma will disclose to the third party job portal provider certain personal information that Ascendis Pharma holds, including but not limited to a unique identifier used by the job portal provider to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that we hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). The third party job portal’s privacy notice in respect of its use of the Disposition Data is available on the third party job portal provider’s website.

Where you have applied to a job opening through another provider, Ascendis Pharma may disclose personal information like the Disposition Data defined above to such provider. The provider shall be the data controller of this personal information and shall therefore be responsible for complying with all applicable law in respect of the use of that personal information following its transfer by Ascendis Pharma.

We process this information for the following purposes:
The information you provide during the recruitment process is used to assess your suitability for employment. Our use of this information is based on our legitimate business interest in recruitment of staff for our business.

If you are successful, the personal information you provide during the application process will be securely retained by us as part of your employee file for the duration of your employment and after termination for as long as required by applicable law. Your personal information is stored on our secure servers within the European Economic Area (“EEA”) and the US.

If you are unsuccessful at any stage of the recruitment process, the information you have provided will be securely retained for up to 6 months from the closure of the recruitment campaign. We retain your information in case any queries or issues arise in relation to the recruitment process, and we need the information to respond to such issues or queries, and/or if a suitable position were to arise at Ascendis Pharma within that time period which we may invite you to apply for.

Automated Decision-making/Profiling
Ascendis Pharma may use Workable’s technology to select appropriate candidates for us to consider based on criteria expressly identified by us, or typical in relation to the position for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who Ascendis Pharma will engage to fill the position will be made by Ascendis Pharma staff.

Who does Ascendis Pharma share my Personal Information with?

  • Workable Software Limited, USA, the provider of our job site.
  • Third party recruitment agencies contracted to assist us with the vetting of job applicants.
  • Third party assessment vendors contracted to perform assessments as part of the recruitment process.

Where you apply for a position via the application function on another job site, you should note that the relevant provider of the job site may retain your personal information and may also collect information from Ascendis Pharma in respect of the progress of your application. Any use by the job site provider of your personal information will be in accordance with the job site provider’s Privacy Statement.

January 2020

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