Janurary 2020
RA Capital knows your privacy is important to you. It is also important to us. Our Privacy Policy explains the types of information that we may collect here at http://www.racap.com/ (the “Site”), how we may use and disclose such information, and how we plan to protect such information, to the extent we collect it. As our firm and the legal landscape evolve, this Privacy Policy may change, so please check this page periodically to ensure you are up to date with our current practices.
The Site is owned and operated by RA Capital Management, LP and its affiliates (referred to collectively in this Privacy Policy as “RA,” “we,” “us,” “our” and other similar pronouns).
WHAT TYPES OF INFORMATION MAY WE COLLECT THROUGH OUR SITE?
• We may collect information from or about Site users concerning use of the Site.
• We may collect Personal Data that you provide directly to us if and when you enter certain information on our Site. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, location, e-mail address, as well as any other non-public information about you that is associated with or linked to any of your data.
Third-party sources. We may collect personal information directly from third parties or combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:
- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Data providers, such as information services and data licensors
- Service providers, that provide services on our behalf or help us operate the Service or our business.
• As is the case with many websites, our servers automatically collect your browser type and IP address when you visit the Site, and we may associate that with your domain name or that of your Internet access provider. In addition, we may capture certain “clickstream data” pertaining to your Site usage. Data captured may include, for example, the referring page that linked you to the Site, the country from which you are conducting your browsing session, the next website you visit when you leave the Site, and any search terms you have entered on the Site or a referral site. See our Cookies and Similar Technologies Notice in this Privacy Policy for more information about how the Site, related services and third-party analytics, advertising and social media companies may use cookies and similar technologies to collect your information when you use the Site.
We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to us and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at ir@racap.com.
RA Capital is headquartered in the United States, and your Personal Data may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your Personal Data may not be as protective as the privacy laws in your home country.
HOW MAY WE USE AND DISCLOSE YOUR INFORMATION?
First and foremost, please do not send or disclose to us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Site or otherwise!If you do send or disclose any sensitive personal information to us (such as when you submit user generated content to the Site), you have consented to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, do not provide it!
We may use your information:
• for purposes that we disclose to you when you submit information to us and in accordance with this Privacy Policy;
• to provide improved administration of our Site;
• to improve the quality of experience when you interact with our Site;
• to respond to your inquiries related to employment opportunities or other requests;
• to send you marketing communications (we may send you RA-related marketing communications which we believe may be of interest to you, but will provide you with the ability to opt out);
• to investigate or prevent violation of the law or our terms and conditions;
• to secure the Site;
• to protect our, your or others’ rights, privacy, safety or property;
• to conduct fraud monitoring and prevention activities;
• to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities or, where permitted by law, in connection with a legal investigation;
• to enforce our terms and conditions;
• to prosecute or defend legal claims; or
• to allow us to pursue available remedies or limit the damages that we may sustain.
In some cases, we may ask for your consent to collect, use or share your Personal Data, such as when you let us post your testimonials or endorsements on the Site. We may perform any of the above functions through our service providers.
We generally do not share information collected about you through the Site. However, if we do collect Personal Data from you, in addition to the circumstances described above, we may share your information among our affiliates for our business purposes in accordance with this Privacy Policy, or in connection with a corporate change or dissolution, including a merger, sale of assets, reorganization, consolidation, bankruptcy, liquidation or wind down of business.
In addition, we may share non-personally identifiable Site usage information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information. The third parties that support our website analytics tools may be able to access and use your Site usage information.
WHEN DO THIRD-PARTY PRIVACY POLICIES COME INTO PLAY?
We maintain presence on several social media platforms, and we may also incorporate some third-party social media features onto the Site. We may also include tools on the Site that allow you to share and/or publicly post content or information from the Site to your profile on a third-party social media platform. Third-party social media platforms have their own privacy policies which explain how they will use, protect and share your information, including any information you share on those platforms from the Site, and we encourage you to read them.
Our Site may contain links or banners that lead to other websites, including investor portals, personal blogs, tweets, and other social media content written or edited by members of our staff, and these sites or entities may collect Personal Data from you. We have no control over, do not review, and are not responsible for these other sites or their content, and so their privacy policies (not this Privacy Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of such websites to understand how your information is treated. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
Information that you may provide, or that we may obtain, through your access to password-protected websites, such as an investor portal, that you may be able to access by following a hyperlink on the Site (each such other website, an “Access-Restricted Website”), is subject to the privacy policies and practices of the operators of the Access-Restricted Website available on such Access-Restricted Website, which we encourage you to read to learn about the treatment of such information.
HOW LONG DO WE RETAIN/KEEP YOUR INFORMATION?
We would only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Additional Information for European Union Users:
References to “Personal Data” or “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. RA Capital is the controller of any of your Personal Data covered by this Privacy Policy for purposes of European data protection legislation and you can contact us using the contact details listed in the Contact Us section of our Site.If we collect any of your Personal Data, we would only use it as permitted by law. We are required to inform you of the legal bases of our processing of your Personal Data, which are described in the bullet points below; if you have questions about the legal basis of how we process your Personal Data, contact us at ir@racap.com:
• if you have entered a contract with us and we need to use your Personal Data to provide services you have requested or take steps that you request prior to providing services;
• to send you marketing communications;
• to deliver you advertising;
• to create anonymous data;
• for security, compliance, fraud prevention and safety; or
• to prosecute or defend legal claims.
These above processing activities constitute our legitimate interests. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Where we rely on your consent for processing, you have the right to withdraw it anytime in the manner indicated in the service or by contacting us at ir@racap.com.
If we collect your Personal Data, we may use your Personal Data for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the applicable legal basis.
European data protection laws give you certain rights regarding your Personal Data. You may ask us to take the following actions in relation to your Personal Data that we hold:
• opt-out from direct marketing communications. You may continue to receive service-related and other non-marketing communications;
• provide you with information about our processing of your Personal Data and give you access to your Personal Data;
• update or correct inaccuracies in your Personal Data;
• delete your Personal Data;
• transfer a machine-readable copy of your Personal Data to you or a third party of your choice;
• restrict the processing of your Personal Data; or
• object to our reliance on our legitimate interests as the basis of our processing of your Personal Data that impacts your rights.
If we collect your Personal Data, you can submit these requests by email to ir@racap.com or our postal address provided in our Contact Us section. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your Personal Data or response to your requests regarding your Personal Data, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here (http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm).
If we transfer your Personal Data out of the European Union/European Economic Area or Switzerland and are required to apply additional safeguards to your Personal Data under European data protection legislation, such as the GDPR, we will do so. Such safeguards may include applying the European Commission's Standard Contractual Clauses described here (https://commission.
WE RESERVE THE RIGHT TO MODIFY THIS PRIVACY POLICY
We may change this Privacy Policy from time to time. When we do, we will let you know by posting the changed Privacy Policy on this page. In some cases, for example, if we make any significant changes, we may tell you about changes by additional means. In some cases, we may request your consent to the changes. Any changes will be effective immediately upon posting to the Site.
CONTACT US
We welcome your questions and comments about privacy. Please feel free to contact us by sending an e-mail to ir@racap.com.
COOKIES AND SIMILAR TECHNOLOGIES NOTICE
Cookies are small data files stored in your browser by a website. They transmit information about your use of the site to its operator or to third parties that placed the cookie. Some cookies are “session cookies” that expire when you close your browser, and others are “persistent cookies” that stay on your computer or mobile device until you delete them.
Our sites and applications may use both session and persistent cookies to enable you to sign in and use our sites and applications, store your preferences and settings within them; analyze how they perform, personalize your experience with them, provide interest-based advertising, facilitate social media interaction and for other lawful purposes. We may also use other similar technologies for these purposes, such as social media widgets that facilitate interaction with social media platforms, unique device identifiers, and third-party software embedded in our mobile applications. In some cases, these cookies and similar technologies are used by third parties.
The cookies and similar technologies used in our Site are as follows:
Most browsers let you remove or reject cookies.
To do this, follow the instructions in your browser settings. Many browsers
accept cookies by default until you change your settings. For more information
about cookies, including how to see what cookies have been set on your computer
or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some
inconvenience on our sites. For example, you may not be able to store
preferences in our sites. If you disable cookies, certain features of our
website may not work.
For more information about targeting and advertising cookies and how you can opt out, you can visit the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or http://youronlinechoices.eu.