Disc Medicine, Inc.
Privacy Policy
This Privacy Notice was last updated on April 14, 2022.
Welcome to the web site (the “Site”) of Disc Medicine, Inc. (“Disc Medicine”, “we”, “us” and/or “our”). The Site is operated by Disc Medicine and has been created to provide information about our company and the services we offer to our Site visitors and users (“you”, “your”). This Privacy Notice (“Notice”) sets forth how we process information including personally identifiable data (“Personal Data”) that is collected from visitors to the Site, and how you may exercise any rights you may have regarding our processing of your Personal Data. Disc Medicine, or any of its subsidiaries or affiliates (“Related Companies”), will be the entity responsible for the collection and processing of your Personal Data (known in some jurisdictions as the data controller).
Information We Collect:
When you interact with us through the Site, we may collect Personal Data and other information from you, as further described below.
Personal Data
We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our prompts, or use certain Site functionality.
We will process any Personal Data we collect in accordance with applicable law and as explained in this Notice.
Below is a summary of our processing activities for the past 12 months, including how we collect, process, and use Personal Data and the potential recipients of your Personal Data. Some jurisdictions require us to state the legal bases for processing your personal Data, which is included below, but please note that not all jurisdictions recognize all legal bases.
| Technical Information Examples of technical information we process: Internet Protocol (IP) addresses, browser type, browser language, device type, advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)), the date and time you use our Site, Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Site, activity on our Site and referring websites or applications, data collected from cookies or other similar technologies**, and geolocation information. Examples of how we use your technical information: amongst other uses, we may use your technical information to protect against and respond to cybersecurity incidents; and to provide you with customized content through our websites. |
| We obtain this Personal Data from: | We process this Personal Data for the following purposes: | We process this Personal Data under the following legal bases: | We may share this Personal Data with: |
| • you directly through the use of our Site • your devices | • to present the Site and its contents to you • to troubleshoot problems with the Site, or any services • to enforce the Site Terms of Use, and to detect and protect against error, fraud and other unauthorized or illegal activities • to attempt to contact you regarding safety issues • to provide any legitimate business service or product • to improve the content and functionality of the Site • to better understand our users and customers • to improve our products and services | • for the purposes of our legitimate interests • in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law* | • Related Companies • partners that assist us with our Site or help us improve our marketing or administration** |
| Contact information: Examples of identity and contact information we process: first and last name, email address, and IP address. Examples of how we use your identity and contact information: amongst other uses, we may use your identity and contact information to communicate with you in response to inquiries you make as a Site visitor to us via our Site. |
| We obtain this Personal Data from: | We process this Personal Data for the following purposes: | We process this Personal Data under the following legal bases: | We may share this Personal Data with: |
| • you directly through the use of our Site • your devices | • to communicate with you • to identify and authenticate you • to protect against malicious or illegal activity • to ensure the appropriate use of our Site • to improve our Site • for administrative purposes • for quality assurance • to improve the content and functionality of the Site • to better understand our users and customers • to improve our products and services • to tell you about product or services we believe will be of interest to you.*** | • for the purposes of our legitimate interests • in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law* | • Related Companies • partners that assist us with our Site or help us improve our marketing or administration** |
*The legal bases relied upon by Disc Medicine under the European Union’s General Data Protection Regulation (“GDPR”) include those enumerated in Articles 6 and 9, depending on the type of Personal Data.
**There are certain circumstances in which we may share your Personal Data with certain third parties.
*** Each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us at: privacy@discmedicine.com.
- Business transfers: as we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
- Agents, consultants and related third parties: Disc Medicine, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
- Legal Requirements: we may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Disc Medicine, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
Other Information:
Non-identifiable data: Next to Personal Data, we also process non-identifiable data. When you interact with us through the Site, we receive and store certain non-identifiable information. We may store such information itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. The Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ internet service providers.
Cookies and similar technologies: In operating the Site, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site features. We may, and we may allow third party service providers to, use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.
Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Notice whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Notice.
Aggregated or de-identified personal data: In an ongoing effort to better understand and serve the users of the Site, we often conduct research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregated and/or de-identified basis, and we may share this aggregated and/or de-identified data with its affiliates, agents and business partners. This aggregated and/or de-identified information does not identify you personally. We may also disclose aggregated and/or de-identified user statistics and other metrics related to our Site in order to describe our products and services to current and prospective business partners, and to other third parties and for other lawful purposes.
Your Choices:
You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain functionality on the Site.
Exclusions:
This Privacy Notice shall not apply to any unsolicited information you provide to us through the Site or through any other means. This includes, but is not limited to, information posted to any public areas of the Site, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.
Children:
We do not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Site. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Notice by instructing their children never to provide Personal Data on the Site without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Site, please contact us, and we will endeavor to delete that information from our databases.
Links to Other Web Sites:
This Privacy Notice applies only to the Site. The Site may contain links to other web sites not operated or controlled by Disc Medicine (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Site do not imply that Disc Medicine endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
Your rights regarding your Personal Data
Under your jurisdiction’s data protection law, you may exercise the following rights with respect to some or all of your Personal Data:
- to request access to your Personal Data (including under GDPR Article 15);
- to request that we rectify or erase your Personal Data (including under GDPR Articles 16 and 17);
- to request that we restrict or block the processing of your Personal Data (including under GDPR Articles 18, 21 and 22);
- to provide your Personal Data directly to another, i.e., a right to data portability (including under GDPR Article 20); and
- when we previously obtained your consent, to withdraw consent to processing (including under GDPR Article 21).
To exercise these rights, please write to us at privacy@discmedicine.com.
California law grants its residents certain rights regarding the collection and use of their personal information. If you are a California resident and would like to exercise your rights, please write us at privacy@discmedicine.com so that our support team can communicate with you and provide assistance regarding your request. Please note that we may require additional information from you or your authorized agent to honor your request and may deny your request if we cannot verify your identity or status as a California resident.
Please feel free to contact us if you have any questions about our Privacy Notice or the information practices of the Site.
You may contact us at: privacy@discmedicine.com
You have the right to lodge a complaint with the relevant Data Protection Authority.
Transfer of Personal Data across national borders
If you provide Personal Data to the Site, you acknowledge that such Personal Data may be transferred from your current location to the offices and servers of Disc Medicine and the authorized third parties referred to herein located in the United States.
Please be aware that Personal Data we collect and process may be transferred and maintained outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location, including the United States. Disc Medicine has put in place safeguards, in accordance with applicable legal requirements, to protect your Personal Data irrespective of the standards in the country where your Personal Data may be transferred. This includes entering into agreements with third parties, such as service providers, to require them to adopt standards that ensure an equivalent level of protection for data as those we adopt.
How long your Personal Data will be retained
We will retain your Personal Data as long as it is necessary to pursue the purposes for which the data is being collected as described above. We may retain Personal Data therefore as long as is reasonably necessary for legitimate business purposes or legal and regulatory purposes.
Security:
We take commercially reasonable steps to protect the Personal Data provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Site may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to us via the internet.
Other Terms and Conditions:
Your access to and use of the Site is subject to the Terms of Use at www.discmedicine.com/terms-of-use/.
Changes to Our Privacy Notice:
The Site and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Notice. We reserve the right to update or modify this Privacy Notice at any time and from time to time without prior notice. Please review this Notice periodically, and especially before you provide any Personal Data. This Privacy Notice was last updated on the date indicated above. Your continued use of the Site after any changes or revisions to this Privacy Notice shall indicate your agreement with the terms of such revised Privacy Notice.