Recursion Pharmaceuticals, Inc. (“Recursion”, “we”, “us”, “our”) sponsors ethically approved clinical trials. We take the protection of personally identifiable information (“Personal Data”) very seriously. This Privacy Notice (the “Notice”) addresses study site personnel (“Data Subjects”) whose Personal Data we may receive in connection with the clinical trials (“Trial” or “Trials”) we sponsor.
Please read this Notice to learn what we are doing with your Personal Data, how we protect it, and how you can exercise your privacy rights.
This Notice does not apply to Personal Data collected by any other means, like Personal Data collected through our public website. This Notice does not apply to Personal Data of our employees or participants in Trials we sponsor.
You are receiving this notice in connection with your participation in conducting a research study sponsored by Recursion Pharmaceuticals.
The laws and regulations governing clinical trials require Sponsors to collect, use and retain certain personal information about study site personnel—individuals who are involved in the conduct of its clinical trials (including principal investigators, sub-investigators, and study personnel). Recursion is required by applicable data protection laws to provide you with certain information about how and why we collect, use, hold and protect your personal information.
Within the scope of this Notice, Recursion generally acts as a data controller for the Personal Data processed in the context of the Trials we sponsor. This means that we alone determine the purpose and means of the processing of your Personal Data.
In some jurisdictions, we are considered a “joint controller” with another organization, such as the study site where the Trial is being conducted. This means that we jointly, together with the other organization, determine the purpose and means of the processing of your Personal Data. If you would like to know more about any other data controllers who might be joint controllers together with Recursion, you may ask the study site for further details.
Personal Data We Collect
When you work on a Trial, we will obtain the following kinds of information about you either directly from you, from the Institution conducting the clinical trial, from the Principal Investigator, or from the contract research organization (CRO):
Identity and Contact Data: such as full name, business and personal address, phone numbers, email address.
Professional Data: such as workplace and address, position, medical specialty, professional qualifications and experience, medical license, training, publications, awards, affiliations, other information included in your CV.
Financial Data: where applicable, information needed for payment processing (e.g., bank account details), and details of any significant financial relationship with Recursion.
Interaction Data: such as your participation in our training sessions, details of our meetings/calls, details of our agreements with you.
Recursion does not collect special category data about you (i.e., about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, genetic and biometric data) unless it is required or permitted to do so by applicable law, or you provided your explicit consent.
Basis of Processing
We may process your Personal Data on the basis of:
Consent: We may ask for your consent to collect and process your Personal Data.
Contract: We may process your Personal Data to fulfill a contract between us and you, or us and the investigative site that employs you.
Compliance with Legal Obligations: We may need to process your Personal Data to comply with applicable laws or regulations, such as the laws regulating the safety and reliability of our Trials.
Legitimate Interests: We may process your Personal Data based on our legitimate interests(which are to carry out and evaluate clinical trials to understand conditions and develop medicines, to ensure safety of its products, to inform decisions from regulatory authorities on access and reimbursement of new treatments for the benefit of patients, and to advance scientific research and medical discovery) and these interests do not prejudice or harm your rights and freedoms.
Public Interest: We may process your Personal Data for reasons of public health interests to ensure adequate standards of quality and safety of the drugs or treatments we are developing.
Where we process your Personal Data based on your consent, you may withdraw your consent at anytime. However, this will not affect the lawfulness of our processing before you withdrew your consent. It will also not affect processing performed on other lawful grounds. If you withdraw your consent, you may be ineligible to participate in conducting a research study sponsored by Recursion Pharmaceuticals.
Where we receive your Personal Data as part of a contract we may have with you or the investigative site that employs you, we require such Personal Data to be able to carry out the contract. Without that necessary Personal Data, we will not be able to fulfill our contractual obligation towards you or the investigative site that employs you.
Where we process Personal Data on the basis of our legitimate interests, we will always do so after a careful assessment which requires balancing your right to privacy and our legitimate interests.
Confidentiality: How We Use Your Personal Data
We use your Personal Data to allow Recursion oversight of the Trial. We are committed to protectingthe confidentiality, integrity, security, and privacy of your Personal Data.
Your Personal Data will become part of the clinical trial databases and clinical trial master file andRecursion (and its chosen contract research organization acting on its behalf) will process your PersonalData on the basis set forth in the Basis of Processing Section. Please note, in certain limitedcircumstances, we may be required to share your Personal Data to comply with the law, regulatoryrequirements, or an enforceable governmental request, to prevent fraud or abuse related to the Trial, orto protect our legal rights.
Recursion (and its chosen contract research organization acting on its behalf) may process your PersonalData, whether in electronic or hard-copy format, for the purposes of:
assessing your suitability to participate in conducting Trials, either as Principal Investigator or a member of the study personnel;
communicating with you about the Trial you are participating in conducting;
managing the conduct of the Trial and your role;
carrying out other Trial activities as required or permitted by laws, regulations and/or guidelines governing clinical trials (including responding to adverse events, drug safety concerns and complaints, medical information inquiries, and performing monitoring visits, inspections, and audits of the clinical trial at the investigative site at which you work);
communicating and corresponding with regulatory bodies relating to the Trial and preparing and submitting regulatory filings;
publicly disclosing payments or benefits in kind (i.e., transfers of value) made to you in connection with the Trial and/or our agreement with you, in accordance with applicable law and pharmaceutical industry codes; and
complying with requests from regulators, courts, law enforcement authorities, government investigators, or in connection with litigation.
Sharing Personal Data with Third Parties
We may share Personal Data with our service providers who process Personal Data on our behalf, and who agree to use the Personal Data only to assist us in fulfilling the purposes of processing as described above, or as required by law. Our service providers include:
Recursion locations in other parts of the world (including the U.S. and Canada);
contract/clinical research organizations appointed by Recursion to carry out certain tasks relating to the Trial;
professional advisors, such as lawyers, insurers and auditors; and
data storage and archiving software and related services;
logistics and transport services;
quality assurance, safety and pharmacovigilance software and related services;
data analytics and reporting software and services;
services related to the collection, storage, testing, and transportation of biological material; and
electronic data capture software and hardware.
Other Disclosures of Your Personal Data
We may disclose your Personal Data:
to regulators or competent authorities, to the extent necessary to comply with applicable laws, regulations, and rules (including, without limitation, federal, state, or local laws);
to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties);
if, in the future, we sell or transfer, or consider selling or transferring, part or all of our company, business, shares, or assets to a third party, and we disclose your Personal Data to such third party in connection with the sale or transfer; or
in the event that we are acquired by, or merged with, a third-party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose, or assign your Personal Data in connection with the foregoing events.
If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.
Your Rights with Respect to Your Personal Data
You may ask to exercise your rights as a data subject, which are described below, by using the information in the “Contact Us” section below. Please note that even if you request access, review, or deletion of your information, it may not occur until after completion of the Trial in order to protect the integrity of the research. In addition, we may not be able to delete certain information about you if necessary to comply with the law.
If we process your Personal Data, you will have the right to request access to (or to update or correct)that Personal Data. This means that you have the right to ask us to confirm whether or not we process your Personal Data, and, where that is the case, obtain a copy of or access to your Personal Data and other related information (such as the purposes for which we collected your Personal Data, and the categories of third parties that we share it with). You can also ask us to correct, without undue delay, anything that you think is wrong with the Personal Data we have about you, and to complete any incomplete Personal Data.
You may also have the right to ask that we limit/restrict our processing of your Personal Data (e.g., if you ask us to only use or store your Personal Data for certain purposes). You have this right in certain circumstances, such as where you have reason to believe the data is inaccurate or the processing activity is unlawful.
You have the right to object to our processing of your Personal Data. We will always strive to fulfill your request. However, please note that there are occasions when doing so may not be possible, like when the law tells us we cannot do that, or where we need your Personal Data to complete the transaction for which we collected the Personal Data.
As discussed under Basis of Processing above, if we requested your consent to process your Personal Data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of our processing before you withdrew your consent. It will also not affect processing performed on other lawful grounds. If you withdraw your consent, you may be ineligible to participate in conducting a research study sponsored by Recursion.
You may also have the right to “data portability”, which means that you may have the right to ask us to provide you with a copy of your Personal Data. If you exercise this right, we will provide you with a copy of your Personal Data in a structured, commonly used and machine-readable format.
You also have the right to lodge a complaint with a data protection regulator in one or more EEA member States, including the Member State of your habitual residence, place of work, or of the alleged infringement of the GDPR. Contact information for the relevant regulators is available at .
Location and International Transfers of Your Personal Data
Recursion has locations in the U.S. and Canada, and vendors and partners located in different countries inside and outside of the European Economic Area. For the purposes set out above, your personal data may be held in any of these locations or any other location. In some cases, the European Commission may not have determined that those countries’ data protection laws provide an adequate level of protection for your Personal Data. When the GDPR applies to the processing of your Personal Data, we will only transfer your Personal Data to third parties in countries which are recognized as providing an adequate level of protection for Personal Data, or who provide appropriate safeguards to protect your Personal Data. These safeguards may include the model data protection clauses approved by the European Commission (i.e., the Standard Contractual Clauses). To access these model clauses, please contact our Data Protection Officer.
Retention of Your Personal Data
Your personal data will become part of the clinical trial master file, which will be retained until the later of (i) the retention period required by applicable law; or (ii) the period required by the Protocol, which may be for a period of up to 25 years after the completion of the Trial. The retention period may be extended if Recursion is required to preserve your personal data in connection with litigation, investigations, and proceedings, or if longer retention periods are required by law.
Safeguards Protecting Your Personal Data
The security and privacy of your personal information is deeply important to us. Recursion takes appropriate steps, including technical, administrative, and physical security measures, to protect personal information against loss, misuse, and unauthorized access, disclosure, and deletion.
If you have any questions about this Notice or our processing of your Personal Data, or you wish to stop participating in conducting the research, you can contact our Data Protection Officer directly using the contact details listed below or contact Recursion’s Compliance Department (). Please allow up to four weeks for us to reply.
Data Protection Representative
While you may contact us at any time, our data protection representative can be contacted about matters related to the processing of your Personal Data.
European Union Representative
We have appointed VeraSafe as our representative in the EU for data protection matters. To contact VeraSafe, please use this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative/ or via telephone at +420 228 881 031.
Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
United Kingdom Representative
VeraSafe has also been appointed as our representative in the United Kingdom for data protection matters. To make an inquiry, please contact VeraSafe using this contact form:https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at +44(20) 4532 2003.
Alternatively, VeraSafe can be contacted at:
VeraSafe United Kingdom Ltd.
37 Albert Embankment
Data Protection Officer
We have appointed VeraSafe as our Data Protection Officer (DPO). While you may contact us directly, VeraSafe can also be contacted on matters related to the processing of Personal Data. VeraSafe’s contact details are:
22 Essex Way #8203
Essex, VT 05451 USA
Changes to this Notice
If we change this Notice, we will publish the revised Notice on our website. We will also update the“ Effective” date.