Last Updated: 10/21/2022

  1. Overview

This Privacy Policy describes how Versanis Bio, Inc. (“we”, or “us”) uses and transmits your information and data collected through the BELIEVE and the BELIEVE Site App mobile applications (the “Medable Service”). By accessing the Medable Service you consent to this Privacy Policy (“Policy”) and the terms defined herein. This Policy is intended to explain how we collect, use and safeguard Personal Information and Data you provide and that we collect through the Medable Service.

  1. Privacy Policy Revisions

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service.  Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).  We recommend that you check this Privacy Policy periodically for any updates or changes.

  1. Personal Information we Collect

Information you provide to us.  Personal information you may provide to us through the Service or otherwise includes: 

  • Contact data, such as your first and last name, email address, mailing address, professional title, organizational affiliation, and phone number. 
  • Identity data, such as national identification number (e.g. Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card. 
  • Communications that we exchange with you, including when you contact us with questions or feedback, through the Service.  
  • Registration Information, such as information that may be related to a product or an event for which you register. 
  • Financial data, such as your income, economic status, financial account numbers, investment holdings and preferences, and ability to invest. 
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection. 

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as: 

  • Data providers, such as information services and data licensors that provide demographic and other information.  

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as: 

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area. 
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access.
  1. How We use Information Collected or Received from You

Identifiable information is any data that could identify you (e.g. your name, date of birth, or address). To make sure your personal information is kept confidential, information that identifies you will not be included in any report generated by the Study Doctor or any study information sent to the Sponsor. Instead, you will be identified by a code. The Study Doctor will keep a list linking your code with your name, so that you can be identified by your coded data, if needed. 

The information collected through the mobile or web-based applications will only include your code and the Sponsor will not be able to identify you from this information alone. Your coded information will be entered into electronic case report forms and sent through a secure server to where it will be stored in secure, cloud-based storage. All storage will comply with local and/or international data security guidelines. 

Personal Information collected as part of participation in a clinical study will be additionally governed by that study’s Informed Consent Form (“ICF”) and any associated privacy policies.

  1. How we share your personal information

People receiving Personal Data are required to keep it confidential. The following groups may have access to your coded information which may be sent and stored:

  • The Sponsor, for the purposes of this study
  • People and companies working with or for the Sponsor, for the purposes of this study
  • Regulatory or other governmental agencies worldwide
  • In the future a new company acquiring or licensing rights from the Sponsor or part of its business
  • Other third parties (which may include third parties in other jurisdictions), including the Sponsor’s partners and vendors.

We may publish the results of this research.  We may also use and disclose your information for research and product development purposes. However, we will keep your name and all other identifying information confidential.

We protect your information from disclosure to others to the extent required by law.

  1. Your Options

You may withdraw your consent for the collection and use of your information at any time, by informing your Study Doctor.  If you withdraw your consent, your study participation will end, and the study team will stop collecting information from you. 

Information from this study may lead to discoveries and inventions or the development of a commercial product. The rights to these will belong to Versanis Bio, Inc. You and your family will not receive any financial benefits or compensation, nor have any rights in any developments, inventions, or other discoveries that might come from this information.

You should ask the Study Doctor if you have any questions about the collection and use of your information. You should also inform your Study Doctor if you wish to exercise your rights about this information, such as if you decide to have some Personal Data corrected or to withdraw consent.

You are also entitled by law to lodge complaint to the Privacy Commissioner if you feel that your privacy has been breached.

  1. Contact Us

If you have any questions regarding this Privacy Policy, you may contact us at info@versanisbio.com.