Privacy Policy

Effective date: December 2022

Last revised: January 8, 2024

Sellas is committed to be a trusted steward of your personal information (please see the “personal information” section below for an explanation of what is considered your personal information).This Privacy Notice (“Notice”) describes how SELLAS Life Sciences Group, Inc. and its affiliates and subsidiaries (collectively, “SELLAS,” “we,” “our” or “us”) collect and process personal information online through www.sellaslifesciences.com and all other SELLAS websites and applications (the “Services”) that link to this Notice. We collect and use this personal information to meet your expectations when you engage with us and continue to improve our business as a late-stage clinical biopharmaceutical company focused on the development of novel therapies for a broad range of cancer indications, dedicated to helping people. Today, we rely on personal information to incorporate state-of-the-art technology into our clinical studies and services, improve quality and safety, and align with the interests of healthcare community, our patients, and other stakeholders. By using the Services, you consent to the processing of your information as set forth in this Notice, now and as amended by us. In addition, you consent to the Website Terms of Use found at the following link: https://www.sellaslifesciences.com/Website-Terms-of-Use

1. WHAT IS PERSONAL INFORMATION?

Personal information is information, or a combination of pieces of information, relating to an identified or identifiable individual. An identifiable individual 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..

2. WHAT PERSONAL INFORMATION DO WE COLLECT

We may collect and process the following categories of personal information from and about you:

• General identification information and contact details, such as a name, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers;
• Demographic information, including characteristics that may be protected by law such as gender or age;
• Biometric information, such as your fingerprints when accessing our facilities;
• Digital data generated from your use of our website, such as IP address, your browser type and version, time zone setting, time period of user’s staying on a single page, the internal path analysis and/or other parameters regarding the user’s operating system and computer environment, browser plug-in types and versions, operating system and platform and other data transmitted via cookies. This data is collected and used only in an aggregated and not immediately identifiable manner; they could be used among others to ascertain responsibility in case of hypothetical crimes against the site or upon public authorities’ request.;
• Audio, electronic, visual, thermal, olfactory, or similar information, such as photographs or voice recordings;
• Professional or employment-related information, such as your employer or title your business address, business email address, business phone numbers, job title/position following any communications that you might have with us where you express your interest in Sella’s activities
• Education information, such as the university you attended and degree; and
• Any inferences that may be drawn from the above categories.

The Services may collect precise information about the location of your mobile device, but only with your express consent. Once you have consented to the collection of the precise location of your mobile device, you may adjust this consent by managing your Location Services preferences through the settings of your mobile device.

3. WAYS OF OBTAINING YOUR PERSONAL INFORMATION

We collect personal information from a variety of sources, including from you directly (e.g., when you contact us via our website, sign up for our newsletters, or submit an application for employment), information we generate about you in the course of our relationship with you (e.g., data collected from cookies and similar technologies as described in our Cookies Policy), and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law). We may also collect certain personal information about you as required by law, or as a consequence of our contractual relationship. Failure to provide this information may prevent or delay the fulfillment of these obligations. Note that we and our service providers may automatically collect certain technical information from your computer or mobile device over time and across different websites when you use the Services.

When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary for us to provide your with additional services, we may not be able to provide you such information.

4. PURPOSE OF PROCESSING YOUR PERSONAL INFORMATION 

We may use your personal information for the following purposes:

• Identification and authentication: We use your identification information to verify your identity when you access and use our Services, or otherwise engage with us, and to ensure the security of your personal information. This is necessary to provide the requested service.
• Service operations: We process your personal information to provide the Services that you request.
• Service improvements: We analyze usage information, including site analytics, to continually improve the user experience. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand issues and make necessary improvements.
• Communications: Communications may include providing information about changes to the terms and conditions, updates regarding our services, employment-related information, or responses to questions you pose.
• Exercising our rights: We may use your personal information to exercise our legal rights where it is necessary to do so, for example to detect, prevent, and respond to intellectual property infringement claims or violations of law.
• Complying with our obligations: We may process your personal information to carry out fraud prevention checks or comply with other legal or regulatory requirements, when required by law.
• Customizing your experience: We may use your personal information to improve your experience of the Services, such as by providing interactive or personalized elements on the Services and providing you with content based on your interests.

We may also anonymize your personal information in such a way that you may not reasonably be re-identified by us or any other company, and may use this anonymized information for any other purpose.

Sellas will process personal data for further purposes, where lawful to do so or when legally obliged to do so.

5. LEGAL BASIS OF PROCESSING

Sellas processes personal data based on one or more of the following conditions:

• Where you have provided your consent (in which cases, such consent can be withdrawn at any time and without giving any reason);
• Where processing is necessary for compliance with a legal obligation to which we are subject (e.g. to comply with our quality and safety obligations);
• Where it is necessary to comply with our contractual obligations towards you; or
• Where we can rely on our overriding legitimate interests.

6. HOW AND WHEN WE SHARE YOUR PERSONAL INFORMATION

The personal information we collect from and about you may be disclosed to third parties for the purposes described in this Privacy Notice.

• To inform third-party entities that provide services to us: We may share your personal information with third parties that perform marketing services and other business operations. For example, we may partner with companies to process secure payments, fulfill orders, optimize services, send newsletters and marketing messages, support email and messaging services, and analyze information. These service providers may include advertising agencies and fraud prevention agencies which will use your personal information only in the ways described in this notice.
• Where required by law: We may share your personal information with law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
• In the context of a transaction: We may share your personal information with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer your personal information to use it in a manner consistent with this Privacy Notice.
• To protect legal rights or the security or integrity of our operations or the Services, protect your safety or the safety of others, investigate fraud, a breach of contract, or a violation of law, respond to a government request, or allow us to pursue available remedies or limit the damages that we may sustain
• To the subsidiaries and affiliates within the Sellas group of companies

7. LINKS TO THIRD-PARTY WEBSITES

This Privacy Notice applies only to the Sites that display or refer to this Privacy Notice. The Services also may contain third-party links. You acknowledge and agree that we are not responsible for the collection, use or disclosure of your personal information by such third parties that are not under our control. We encourage you to review the privacy policies of each website you visit to learn about how those third parties process your personal information.

8. YOUR RIGHTS OVER YOUR PERSONAL INFORMATION 

You may have certain rights regarding the personal information we hold about you, subject to local data protection law. These rights may include:

1. The right to withdraw your consent at any time, if we are processing your personal information on the basis of consent,
2. The right too access and/or update the personal information that Sellas holds about you,
3. The right to request that Sellas rectify or erase your personal information,
4. The right to request that Sellas restrict the way it processes your personal information,
5. The right to object to the way Sellas processes your personal information,
6. Where you request us to do so, to transfer your personal information either back to you or to another individual or entity, and
7. The right to express your point of view in the event of any individual decision having a significant impact on you being made by automated means about you and to request that such automated decision be reviewed by a human.

If we do not handle your request in a timely manner, or if you are not satisfied with our response to any exercise of these rights. You also may have a right to lodge a complaint with your local data protection or privacy regulator.

If you are based in EU/EEA you also have the right to lodge a complaint with a data protection authority in your country of residence (all EU/EEA Data Protection Authorities’ contact details may be found here).

We also encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. Where you have provided your consent to any use of your personal information, you can withdraw this consent at any time. Please note that we may require additional information from you in order to honor your requests.

We will require appropriate evidence of your identity or to be provided with additional relevant personal information based on your relationship with us before we are able to act on your request in circumstances where the personal information we have in our systems is insufficient detail to identify you or reply to your request.

If you would like to discuss or exercise any rights you may have under law, please contact us at .

For additional information regarding your rights related to our use of cookies, please see our Cookies Policy.

9. CHILDREN’S INFORMATION

The Services are not directed to, nor do we knowingly collect information from, children under the age of 18. We are committed to protecting the privacy of children and that is why we do not knowingly collect personal information from children under the age of 18, unless permitted to do so by applicable law. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at the contact information listed below. If we learn that we have collected personal information directly from children through our Sites without being permitted to do so by applicable law, we will delete this information

10. DATA RETENTION

Unless indicated otherwise in this Privacy Notice, the criteria we use to decide how long we retain personal information include: (i) whether we need your personal information to perform a contract to which you are subject, to respond to your questions or provide to you with the required service or support, (ii) whether there is a legal obligation to which we are subject, or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

We delete personal information when it is no longer necessary to retain it for the purposes described in this Privacy Notice, or when required to do so by applicable law.

11. SECURITY

We strive to have administrative, technical, and physical safeguards designed to protect the information collected by the Services. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the Internet and wireless networks.

12. INTERNATIONAL DATA PROCESSING & TRANSFER

Information collected through the Services will be processed in and subject to the laws of the United States, which, if you are not located in the United States, may not provide the same level of protection for your personal information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information. For example, if you are located in the European Economic Area (EEA), the United Kingdom (UK) or Switzerland and your personal information are transferred to Sellas, meaning in United States, or to Sella’s third-parties in other countries which have different standards of data protection to the EEA, UK and Switzerland, such transfers are governed by Standard Contractual Clauses, where appropriate, or other legally recognized measures that adequately protect the personal information.

For more information on the appropriate safeguards in place, and to obtain a copy of such safeguards, please contact us at the contact information set forth below.

13. CONTACT US

If you have questions or concerns regarding the way in which your personal information has been used, please contact us at .

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country of residence.

14. CHANGES TO THE NOTICE

We may update this Privacy Notice from time to time. If we update this Notice, we will notify you by posting a new Privacy Notice on this page. If we make any changes that materially change the ways we process or protect your information, we will provide additional notification of the changes. When we update this Privacy Notice, we will indicate when it was most recently updated by changing the “last updated” date. Unless otherwise indicated, updates to this Privacy Notice are effective immediately upon posting.

COOKIES POLICY

Introduction and scope

SELLAS Life Sciences Group (Times Square Tower, 7 Times Square, Suite 2503, New York, NY 10036 (646)-200-5278), URL:  https://www.sellaslifesciences.com (SELLAS) and cookies used in this website.

This policy will explain how this website is using cookies to provide clear and relevant information to you, the user, on what choices you have in terms of controlling what happens when you access our website. The policy uses the term ‘cookies’ to refer to cookies and similar technologies covered by the law (such as, for example, Local Shared Objects – commonly referred to as “flash cookies”, web beacons or bugs, including transparent clear gifs). The gathered information concerns data that could allow to identify web users/visitors by associating and processing them with other data kept by third parties (such as, for example, the IP address, domain, and registration numbers of the computers used by people connecting to the website). These data are used and processed only for statistical purposes.

This documents is an integral and substantial part of the Privacy Policy. We recommend, therefore, that you also read our Privacy Policy to know more about SELLAS’ general commitment to data protection.

What is a cookie?

A cookie is a small text file typically consisting of letters and numbers, downloaded on to a device when you access the website. Cookies are then sent back to the originating website on each subsequent visit. Cookies help analyze web traffic and lets you know when you visit a particular site. Cookies allow web applications to respond to your individual preferences when online and tailor operations by gathering and remembering information about your preferences, providing you with a more personalized experience.

Cookies help SELLAS provide a better user experience on our website by monitoring which pages are most frequently visited. Cookies do not give SELLAS access to your computer or provide any information other than the data you choose to share. Therefore, you are given the choice to directly accept all of them or to customize your cookies preferences.

Different types of cookies

Session and persistent cookies

Cookies can expire at the end of a browser session (from when you open the browser window to when you exit the browser) or they can be stored for longer periods of time.

Session cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user had put in their shopping basket as they browsed around a site. These session cookies expire after a browser session. The use of the these session cookies (that, in any case, are not stored persistently on the user’s computer and are deleted automatically as soon as the browser is shut down) is strictly limited to the purpose of transmitting data (made up of random numbers created by the server), identifying the specific session and information necessary to allow safe and efficient website browsing. The session cookies used in this website avoid any other computer methods that could potentially compromise the privacy about a user’s web-surfing.

Persistent cookies – are stored on a user’s device in between browser sessions, which allow the preferences or actions of the user across a site (or in some cases, across different websites) to be remembered. Persistent cookies may be used for a variety of purposes, including remembering a user’s preferences and choices when using a particular site.

First and third-party cookies – whether a cookie is first- or third-party cookie refers to the website or domain placing the cookie. First-party cookies in basic terms are cookies set by a website visited by the user – the website displayed in the URL window (e.g., cookies set by SELLAS on https://www.sellaslifesciences.com). Third-party cookies are cookies that are set by a domain other than the one being visited by the user (i.e., cookies which are set by companies and websites other than SELLAS, such as Google). If a user visits a website such as this one and a separate company sets a cookie through this website, that separate company’s cookies would be a third-party cookie.

To exercise your cookie preferences, you may also visit:

https://optout.aboutads.info/ or https://www.networkadvertising.org/

Cookies that we use

When operating this website, SELLAS uses cookies to improve the user’s experience, as well as to develop aggregated statistics on the data collected for various reasons.

These cookies allow us to distinguish you from other users of the website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our website.

The cookies we use are “technical” and “analytical” cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the site when they’re using it. This helps us to improve the way our website works, for example, by making sure users are finding what they need easily. Read more about the individual analytical cookies we use and how to recognize them from the table below.

Strictly necessary cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as a result. These cookies do not store any personally identifiable information.

Performance cookies 

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, length of time spent on the site, and if they get error messages from web pages. These cookies don’t collect information that identifies you. All the information that these cookies collect is anonymous and is only used to improve how a website works.

Analytics

This website uses analytics to help improve both the user experience and functionality. SELLAS uses external services, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies,” which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of certain cookies by selecting the appropriate settings on your browser.

However, please note that if you refuse certain cookies, you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

For more details on how Google processes your data, please visit Google’s Privacy Policy.

To opt out of being tracked by Google Analytics across all websites (not just SELLAS), visit https://tools.google.com/dlpage/gaoptout (compatible with Chrome, Internet Explorer 8–11, Safari, Firefox and Opera).

Third-Party Cookies

Our website also uses additional external services. These external services may employ the use of cookies. More information on these external services and their data/privacy policies can be found by following the link(s) below:

• DoubleClick privacy policy: https://policies.google.com/privacy?hl=en

SELLAS does not control any third party’s use of cookies or their privacy notice compliance. Users should use caution when accessing these external services.

How to accept, control, and delete our cookies

Some cookies are strictly necessary for the correct functioning of this website and do not require user’s consent, such as those ensuring that the content of a page loads quickly and effectively by distributing the workload across numerous computers or those providing security.

Other cookies are still reasonably necessary or important, but they are not strictly essential and, therefore, require user’s consent. For these cookies (i.e., performance and functionality), we request your consent (by the “accept all cookies” button in our cookie banner or through your browser cookie settings) before placing them on your device.

If you do not wish to give consent or wish to withdraw your consent to any non-essential cookies at any time, you will need to delete, and block or disable cookies via your browser settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. Otherwise, you should use the ‘help’ option in your internet browser for more details or you can click on one of the links below to go directly to the user manual for your browser:

Mozilla Firefox

Google Chrome

Safari

Opera

Internet Explorer

Please note that disabling or blocking some or all the categories of cookies will affect the functionality of the website and may impact your access and experience with our website.

Any of your cookies preferences are limited to this website only and not to other third-party owned websites or any other webpages, which may be hyperlinked to this website. For more information on cookies used by those websites, please refer to the specific privacy notice or cookie policy of those websites.

Circulation and storage of data

Data concerning website users will not be stored for a longer period than the above mentioned for each cookie type, except for any need of checking computer crimes damaging the website in compliance with applicable laws. No information coming from the web service will ever be either communicated or disseminated to unspecified recipients.

Cookies policy updating

The cookies policy of our website may be updated periodically, so it is recommended to consult this document when you access the site in order to be properly informed about any updates to our use of cookies.