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Innovation. Clarity. Execution.  I  Data Protection Policy

Data Protection Policy.

1.   Introduction

This Policy sets out the obligations of Advent Life Sciences LLP, a limited liability partnership company registered in the UK under number OC347034, whose registered office is at Advent Life Sciences LLP, 27 Fitzroy Square, London, W1T 6ES, (“the Company”) regarding data protection and the rights of investors and related contacts, partners, employees, contractors and other business contacts (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

2. The Data Protection Principles

This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply:

2.1  The Company processes personal data lawfully, fairly and in a transparent manner;

2.2  The Company collects personal data only for specified, explicit and legitimate purposes;

2.3  The Company processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing;

2.4  The Company keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay;

2.5  The Company keeps personal data only for the period necessary for processing; and

2.6  The Company adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

3. The Data Protection Principles

3.1 The Company tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.

4. Lawful, Fair, and Transparent Data Processing

4.1 The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:

4.1.1 The data subject has given consent to the processing of their personal data for one or more specific purposes;

4.1.2  The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;

4.1.3  The processing is necessary for compliance with a legal obligation to which the data controller is subject;

4.1.4  The processing is necessary to protect the vital interests of the data subject or of another natural person;

4.1.5  The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or

4.1.6  The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

5. Specified, Explicit, and Legitimate Purposes

5.1 The Company only collects, processes, and holds personal data for the specific purposes and other purposes expressly permitted by the GDPR.

5.2 Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data.

6. Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed).

7. Accuracy of Data and Keeping Data Up-to-Date

7.1 The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject.

7.2 The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

8. Data Retention

8.1 The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.

8.2 When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

9. Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage.

10. Accountability and Record-Keeping

10.1 The Persons responsible for data protection compliance are the General Partners of the Company. The General Partners are assisted by Rowena Patel with regards to GDPR compliance and can be
contacted at

10.2 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

10.2.1 The name and details of the Company and any applicable third- party data processors;

10.2.2 The purposes for which the Company collects, holds, and processes personal data;

10.2.3 Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;

10.2.4 Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;

10.2.5 Details of how long personal data will be retained by the Company; and

10.2.6 Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

11. Data Protection Impact Assessments

The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data which involve the use of new technologies and whether the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR.

12. Keeping Data Subjects Informed

12.1 The Company shall provide the following information for Part 11 to every data subject:

12.1.1 Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and

12.1.2 Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:

a) if the personal data is used to communicate with the data subject, when the first communication is made; or

b) if the personal data is to be transferred to another party, before that transfer is made; or

c) as soon as reasonably possible and in any event not more than one month after the personal data is obtained.

12.2 The following information shall be provided:

12.2.1 Details of the Company;

12.2.2 The purpose(s) for which the personal data is being collected and will be processed and the legal basis justifying that collection and processing;

12.2.3 Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;

12.2.4 Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;

12.2.5 Where the personal data is to be transferred to one or more third parties, details of those parties;

12.2.6 Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place.

12.2.7 Details of data retention;

12.2.8 Details of the data subject’s rights under the GDPR;

12.2.9 Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;

12.2.10Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the GDPR);

12.2.11 Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it.