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Privacy Policy

October 30, 2020

1. Introduction to Privacy Notice
1.1 Argenta is committed to protecting your privacy. This notice describes how we collect and use your personal data including through our website at www.argentaglobal.com (Website). It also describes the rights you have and control you can exercise in relation to it.
1.2 This Privacy Notice should be read in conjunction with our Website Terms of Use which is incorporated by reference into this Privacy Notice.
1.3 This Privacy Notice is effective as at the date set out at the top of it.
1.4 Do not use our Website or provide us with any of your personal information if you do not agree to this Privacy Notice.

2. Definitions
2.1 In this Privacy Notice, we use the terms ‘personal information’, ‘personal data’ and ‘sensitive information’.  
2.1.1 ‘Personal information’ is defined in the Privacy Act 2020 (New Zealand) and means information about an individual that identifies the individual. In some jurisdictions personal information or its alternative term, personal data, also includes opinions about individuals where the individual can be identified or identifiable and also includes information that could be used to identify, locate, contact or track behaviour or preferences of an individual and so we also mean to include those things when we use the term personal information or personal data in this Privacy Notice.
2.1.2 ‘Sensitive information’ or ‘special categories’ of personal information mean information revealing the individual’s racial or ethnic origin, religious beliefs or philosophical beliefs or health data, their political opinions, trade union membership, genetic data, biometric data (where used for identification purposes), data concerning their sex life or sexual orientation or criminal record.
2.1.3 A ‘data subject’ is the person who is the subject of the personal information.
2.1.4 A ‘data controller’ is the legal person which alone or jointly with others determines the purposes and means of processing of personal data.
2.1.5 A ‘data processor’ is the legal person who processes personal data on behalf of the data controller.

3. Data controller Information about Argenta and how to contact us
3.1 Who we are: ‘Argenta’ is the trading name of Argenta Limited (New Zealand company number 1846126), of address 2 Sterling Avenue, PO Box 75 340, Manurewa 2102, Auckland, New Zealand.  Our telephone number is +64 9-250 3100.
3.2 The terms ‘Argenta’ mean one or more of our affiliates (‘we’/’us’/’our’) and all of them are referred to in this Privacy Notice as the Argenta Group.  Any reference to an Argenta ‘location’ means any office or facility of ours around the world.
3.3 Personal data is collected by each member of the Argenta Group.
3.3.1 In the United Kingdom our primary data collector is Argenta Dundee Limited (Kinnoull Road, Dundee, DD2 3XR, Scotland, United Kingdom with registration number SC553262);
3.3.2 In the United States of America our primary data collectors are AlcheraBio, LLC, D/B/A Argenta (409 Joyce Kilmer Ave, Suite 112, New Brunswick, NJ 08901, USA, with registration number 06-1805112) and AML Riverside, LLC (141 East Riverside Drive, Fort Dodge, IA 50501, USA, with corporation number 478321); and
3.3.3 In New Zealand our primary data collectors are Argenta Limited (2 Sterling Avenue, PO Box 75 340, Manurewa 2102, Auckland, New Zealand, with company number 1846126).
3.4 Data controller:  Argenta Limited is the data controller for the personal information that we and members of the Argenta Group process unless otherwise stated.
3.5 If you have any questions about Argenta’s use of your personal data, please use the following contact: Argenta Limited, 2 Sterling Avenue, PO Box 75 340, Manurewa 2102, Auckland, New Zealand or telephone number +64 9-250 3100 or DataProtection@argentaglobal.com.

4. Data Collection and Use
4.1 Argenta does not collect personal data about your online activities across third party websites or online services.
4.2 What we collect: We will collect the following personal data:
4.2.1 Contact information: your name, position, role, company or organisation, telephone (including mobile phone number where provided) as well as email and postal address;
4.2.2 Business information: data identifying you in relation to matters on which you engage with us or in which you are involved;
4.2.3 Your logon ID and password: for access to our extranets and other customer services or platforms;
4.2.4 Information from public sources: e.g. LinkedIn and similar professional networks, directories or internet publications;
4.2.5 Information in connection with investigations or proceedings: where this is necessary to conduct the investigation or proceedings;
4.2.6 Attendance records: to record your attendance at our offices for security purposes;
4.2.7 Subscriptions/preferences: when you subscribe to receive updates or newsletters as well as consent preferences to help us identify which materials you are interested in receiving;
4.2.8 Events data: attendance at and provision of feedback forms in relation to our events;
4.2.9 Supplier data: contact details and other information about you or your company or organisation where you provide services to us;
4.2.10 Social media: posts, likes, tweets and other interactions with our social media presence;
4.2.11 Technical information: when you access this website and our technology services being IP address, browser type and version (e.g. Internet Explorer, Firefox, Safari etc.), time zone setting, browser plugin types and versions, operating system you are using (e.g. Vista, Windows XP, MacOS, etc), device type, hardware model, MAC address, unique identifiers and mobile network information;
4.2.12 Online data: when you access this website and our technology services, information about your visit including URL clickstream to, through and from our website (including date and time), information about your network as such as information about devices, nodes, configurations, connection speeds and network application performance; pages viewed or searched for, page response times, download errors, length of visits and interaction information (such as scrolling, clicks, mouse-overs) and whether you click on particular links or open our emails.  
4.2.13 Communications data:  We may also collect information that you choose to provide in communications with us.  Please do not send us confidential information until we have confirmed in writing that we represent or act for you or your company or organisation. Unsolicited emails from non-clients do not establish a lawyer-client relationship.  They may not be privileged and, therefore, may be disclosed to others.
4.3 Special categories of personal data: such as:
4.3.1 dietary, disability or similar requirements for events and meetings.  If you do not provide this information, we may not be able to respond to your particular needs or preferences.
4.3.2 criminal record data: where permitted by national law and appropriate to do so, such as existence of prior criminal offences (or confirmation of clean criminal record);
4.3.3 other including health data:  if you provided it to us or your employer, or referee does, or from the company or organisation who is our customer credit or customer/employee screening providers who assist us with our legal obligations to conduct under anti-money laundering, sanctions screening, animal welfare or modern slavery or other regulatory checks.


5. When and how we collect
5.1 The personal data will be provided to us by you, your current or former employer, the company or organisation who is our customer or supplier, or screening providers who assist us with our legal obligations to conduct under credit, employment, supplier, anti-money laundering, sanctions or other screening and other regulatory checks.
5.2 We collect personal information online through our Website and other online resources when we collaborate with other online service providers from which we may receive personal information about users of such resources.  These online collaborations are governed by agreements that require personal information to be protected appropriately.
5.3 We can collect personal information in a number of ways including the following:
5.3.1 Through information collected from your computer or other electronic device: We collect information about your use of a computer or other electronic device when you visit our Website or use online resources.  This information may include your internet protocol (IP) address, internet service provider (ISP), domain name, browser type, date and time of your request and information provided by tracking technologies, such as cookies, single-pixel tags, local share objects (flash), local storage, etags and scripts.  If you leave our Website without becoming a registered user we may use cookies in conjunction with third parties to serve advertisements to your computer or other electronic device to remind you about our Website that you had previously visited.  Please see the below section on cookies and how you can control them.  If you use a mobile device to access our Website we may collect information about your device, such as your device ID or device type, as well as usage information about your device and your use of our mobile Website.
5.3.2 Through information that you provide: We collect personal information that you may enter into forms or data fields on our Website or other online resources such as your contact information (such as your name, address, email address, telephone number, user ID and password, date of birth, professional credentials, activities and preferences.
5.3.3 Through information from public or third-party information sources: We may collect personal information about business contacts who register on our Website from public or third party information sources to verify their professional credentials and identity.  When customers enter into an agreement with us, we may verify their credit information with financial or credit organisations.  When potential employees contact us, we may verify their professional credentials and experience with third party referees, learning institutions and former employers.  We may augment our existing user databases with information from third parties.
5.3.4 Through information by listening to social media and third parties:  We may also collect personal information about you from public internet source including social networking, forums, conferences, wikis, and podcasts.

6. How we use your personal data
6.1 We use your personal data for the following purposes:
6.1.1 Product and service provision: Providing products and services.
6.1.2 Business relationship: managing and administering our relationship with you, your company or organisation including keeping records about business contacts, services and payments so we can customise our offering for you, develop our relationship and target our marketing and promotional campaigns.
6.1.3 Communication: sending emails, newsletters and other messages to keep you informed about our products and services.
6.1.4 Events: running events.
6.1.5 Customer surveys and feedback: including events feedback and customer listening exercises as well as answering issues and concerns which may arise.
6.1.6 Legal compliance: Conducting customer or supplier or employee due diligence (under anti-money laundering, sanctions screening and other crime prevention and detection laws and regulatory requirements) which may involve automated screening checks to ensure that contacts are genuine and to prevent fraud or crime and we may not be able to provide you with goods or services or a response if you do not provide the information we need to do these checks.
6.1.7 Website monitoring: to check the website and our other technology services are being used appropriately and to optimise their functionality.
6.1.8 Site security: to provide security to our offices and other premises (normally collecting your name and contact details on entry to our buildings).
6.1.9 Online security: protecting our information assets and technology platforms from unauthorised access or usage and to monitor for malware and other security threats.
6.1.10 Regulatory: compliance with our legal and regulatory obligations as research and manufacturing organisation including auditing and reporting requirements.
6.1.11 Managing suppliers: who deliver services to us.  We may use other companies to deliver email communications on our behalf or to place our advertisements on other Websites such as Google.

7. Our reasons for using your personal data
7.1 Why:  We will process your personal data for a number of reasons:
7.1.1 you have given us consent: for example where you share details for particular purposes;
7.1.2 this is necessary to comply with legal or regulatory obligations;
7.1.3 this is necessary to deal with legal claims;
7.1.4 processing is necessary for our legitimate business interests or those of a third party provided this does not override any interests or rights that you have as an individual.
7.2 Legitimate interests:  We have legitimate business interests in:
7.2.1 providing contract research or manufacturing and supply of goods or services;
7.2.2 managing our business and relationship with you or your company or organisation;
7.2.3 understanding and responding to inquiries and customer feedback;
7.2.4 understanding how our customers use our services and websites;
7.2.5 identifying what our customers want and developing our relationship with you, your company or organisation;
7.2.6 improving our services and offerings;
7.2.7 receiving information from other Argenta locations for shared customers or suppliers;
7.2.8 enforcing our agreements with you including our Website Terms of Use;
7.2.9 ensuring our systems and premises are secure;
7.2.10 managing our supply chain;
7.2.11 developing relationships with business partners;
7.2.12 ensuring debts are paid;
7.2.13 operating suppressors to exclude you from direct marketing if you unsubscribe;  
7.2.14 sharing data in connection with acquisitions and transfers of our business.

8. Our reasons for using special category data
8.1 We will process sensitive data or special category this data where:
8.1.1 we have your explicit consent: for the particular processing;
8.1.2 this is necessary to protect your vital interests or those of another person: for example, in medical emergencies;
8.1.3 you have manifestly made the data public: for example, where you have published it on social media;
8.1.4 this is necessary to deal with legal claims: for example, involving court proceedings;
8.1.5 this is necessary for substantial public interest: for example to prevent or detect unlawful acts;
8.1.6 as permitted by applicable law.

9. With whom do we share your personal data?
9.1 We share your personal information as with others as follows:
9.1.1 Argenta Group members including their management, lawyers, staff and contractors in order to provide our goods and services;
9.1.2 Suppliers who support our business including IT and communication suppliers, outsourced business support, marketing and advertising agencies, legal service providers, back up and disaster recovery suppliers and contractors who provide operational support (such as for administration, sales, marketing, legal, system administration, mail carriers, hosting providers, IT companies, and communications agencies).  Our suppliers have to meet minimum standards as to information security and they will only be provided data in line with their function.
9.1.3 Shared service centres: operated by Argenta Group members or third parties including for customer on-boarding, IT services, marketing, risk management and office support services;
9.1.4 Law enforcement bodies and our regulators: or other competent authorities in accordance with legal requirements or good practice;
9.1.5 Appropriate parties in the event of emergencies: in particular to protect health and safety of our customers, staff and organisations;
9.1.6 Your company or organisation: in relation to us providing goods and services;
9.1.7 Screening service providers: so that we can comply with legal obligations in relation to the prevention or protection of crime, ant-money laundering, sanctions screening and other required checks;
9.1.8 Advertising networks and analytics service providers: to support and display ads on our website, apps and other social media tools;
9.1.9 Third parties: in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation;
9.1.10 Other delegates: where your name will appear on the attendee list for events where you have told us you plan to attend.

10. Transfers of your personal data outside your jurisdiction  
10.1 Because of the international nature of our business, we may need to transfer your personal data to other Argenta Group members, and to other third parties as noted in above, in connection with the purposes set out in this Privacy Notice.  We may transfer your personal data to recipients in other countries.
10.1.1 EEA/European Union and UK:  Where we transfer Personal Data from the EEA, European Union or UK to a recipient outside those locations that is not in an ‘adequate jurisdiction’, we do so on the basis of Standard Contractual Clauses.
10.1.2 Other countries:  We may transfer your personal data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.  Such transfer is not based on or protected by Standard Contractual Clauses but we put in place contractual requirements aimed to ensure that the recipients process the data in compliance with applicable law and the provisions of this Privacy Notice.

11. Personal data about others
11.1 In some cases, you may provide personal data to us about other people (such as your customers, directors, officers, shareholders or beneficial owners). You must ensure that you have given those individuals an appropriate notice that you are providing their personal information to us and have obtained their consent to that disclosure.

12. Security
12.1 We aim to hold your personal information securely in line with physical, technical and administrative security measures. However, the transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your information transmitted and any transmission is at your own risk.

13. Where will your information be held?
13.1 We are a global business and your information may be transferred out of your local jurisdiction or region. Data protection laws vary by country and those applicable in the UK, EU, USA or Australia and elsewhere are not equivalent to those applicable in, for example, New Zealand or certain other jurisdictions.
13.2 We will, take steps to protect your information in line with locally applicable data protection requirements.  
13.3 For those who work with our UK or EU based Argenta Group members, for example, we have implemented Standard Contractual Clauses (SCCs) approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation.

14. How long do we keep your data?
14.1 We generally keep your information as needed to provide our products and services and to deal with claims and as required by applicable laws.  This will depend on a number of factors such as whether you or your company or organisation are an existing customer or have interacted with recent mailings or bulletins or attended recent events.  
14.2 We will retain your information as necessary to comply with legal, accounting or regulatory requirements. Typical retention periods will range from 3 to 15 years.

15. Your Rights
15.1 For UK and EU based data subjects:  If you are working with one of our UK or EU based Argenta Group members, or in certain other jurisdictions where similar rules apply, you have certain rights in relation to your personal information. The availability of these rights and the ways in which you can use them are set out below in more detail.
15.2 Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact the relevant data privacy contact as listed in this Privacy Notice above.
15.2.1 Access: you are entitled to ask us if we are processing your personal data and, if we are, you can request access to your personal data.  This enables you to receive a copy of the personal data we hold about you and certain other information about it.
15.2.2 Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.
15.2.3 Erasure: For UK and EU based data subjects, you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.  There is no ‘right to be forgotten’ in New Zealand privacy law, but there is a limited right for a data subject to request that we make a correction to that information. Such a correction may be by way of a deletion of information. In addition, the Harmful Digital Communications Act 2015 (New Zealand) has provided a right for individuals to apply to the District Court of New Zealand for a take-down order.
15.2.4 Restriction: For UK and EU based data subjects, you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
15.2.5 Transfer: For UK and EU based data subjects, you may ask us to help you request the transfer certain of your personal data to another party.
15.2.6 Objection: For UK and EU based data subjects, where we are processing your personal data based on a legitimate interest (or those of a third party), you may challenge this.  However, we may be entitled to continue processing your personal information.
15.2.7 Direct marketing:  You have the right to object where we are processing your personal information for direct marketing purposes.
15.2.8 Automated decisions: FOR UK and EU based data subjects, you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
15.2.9 Consent: where we are processing personal data with consent, you can withdraw your consent.
15.3 If you want to exercise any of these rights, please contact the data privacy contact set out in this Privacy Notice above, in writing at the relevant email address.
15.4 You may choose not to provide any personal information to us online by electing not to enter any personal information into a form or data field on our Website.  However, some of our online resources require users to identify themselves in order to use personalised services or advanced features which will not be available without such data.  We may not be able to provide you with our services or Website if we do not process your personal information unless we have a lawful means to do that.  Do not use our Website if you do not agree to this Privacy Notice.
15.5 Some of our online resources may request your permission to use and disclose personal information about you in order to add you to our contact lists or to identify and offer additional services that we believe you might find interesting.  You can limit the use of personal information about you by checking or un-checking options provided at the time that you enter that information or that we may offer to you in the future.  Additionally, you may change your communications preferences (such as to opt-out of communications you requested previously) by using the opt-out link provided in our electronic communications or by contacting us at the address most relevant to you.
15.6 Our online resources that use tracking technologies, such as cookies, to remember your personal preferences and selections, enable you to choose whether you want us to use such technologies to remember you, or to provide additional services to you, by checking or un-checking options provided during registration, or at the time that you enter personal information into forms or data fields.  Individual users can control the use of certain tracking technologies, such as cookies, through most internet browsers as set out above in the cookies section.  

16. Complaints
16.1 Complaints:  You also have a right to lodge a complaint with the relevant data protection supervisory authority:
16.1.1 In New Zealand, this is the Office of the New Zealand Privacy Commissioner at https://www.privacy.org.nz/about-us/contact/
16.1.2 In Australia, this is the Office of the Australian Information Commissioner at https://www.oaic.gov.au/about-us/contact-us/
16.1.3 In the UK and EU, this may be the Information Commissioner’s Office (https://ico.org.uk) or the regulator in the Member State in the European Union where you are habitually resident where we are based or where an alleged infringement of data protection law has taken place. In the UK you can make a complaint to the Information Commissioner's Office (Tel: +44 (0)303 123 1113 or at www.ico.org.uk ).
16.1.4 In the United States of America, the Federal Trade Commission (FTC) is broadly empowered to bring enforcement actions to protect consumers against unfair practices including a failure to comply with privacy promises.  You can contact them at:  https://www.ftc.gov/enforcement

17. Direct Marketing
17.1 As described above, data subjects can opt-out of receiving direct marketing from us at any time.
17.2 We may use the information you give us on our website or other means for direct marketing purposes to provide emails, newsletters and other messages to keep you informed of developments, market insights and of our products and services including events that we think may interest you.
17.3 You can opt-out of receiving direct marketing from us at any time. You can do this by changing your marketing preferences on your online accounts settings page, clicking on the ‘unsubscribe’ link included at the end of any marketing email we send to you, or by contacting the data protection contact listed above.

18. Cookies
18.1 What are cookies?  Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why.
18.2 What do we use and why:


18.3 How do I change my cookie settings?  Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org  or www.allaboutcookies.org.  Find out how to manage cookies on popular browsers:
18.3.1 Google Chrome:  https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en
18.3.2 Microsoft Edge:  https://support.microsoft.com/en-au/help/4468242/microsoft-edge-browsing-data-and-privacy
18.3.3 Mozilla Firefox:  https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectslug=enable-and-disable-cookies-website-preferences&redirectlocale=en-US
18.3.4 Microsoft Internet Explorer:  https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
18.3.5 Opera:  https://www.opera.com/help/tutorials/security/privacy/
18.3.6 Apple Safari:  https://support.apple.com/en-gb/safari
18.4 To find information relating to other browsers, visit the browser developer's website.
18.5 To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout

19. Links to third party websites
19.1 Our website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others. The personal data that you provide through these websites is not subject to this privacy notice and the treatment of your personal data by such websites is not our responsibility.
19.2 If you follow a link to any other websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites.

20. Children
20.1 We do not knowingly collect information from children or other persons who are under 16 years old. If you are under 16 years old, you may not submit any personal data to us.

21. Changes to this Privacy Notice
21.1 This privacy notice may be changed from time to time.
21.2 If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.