Privacy Policy

What does this Privacy Policy Cover?

Eliem Therapeutics respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available the website (“Site”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

Who we are and how to contact us.
Your rights relating to your Personal Data.
Marketing communications preferences.
What Personal Data we collect.
How we use your Personal Data and why.
What happens when you do not provide necessary Personal Data?
How we use cookies & other tracking or profiling technologies.
Who we share your Personal Data with.
When and how we transfer data outside the UK.
How we keep your Personal Data secure.
How long we store your Personal Data.
Our policy on children.
Third party links.

This Privacy Policy aims to give you information on how Eliem Therapeutics collects and processes your Personal Data through your use of this Site, including any data you may provide through this Site.

The Privacy Policy is intended to meet our duties of transparency under the General Data Protection Regulation as that regulation is incorporated into United Kingdom law by the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (the “UK GDPR”).

We will post any modifications or changes to this Privacy Policy on this page or a successor page we may notify to you from time-to-time.

Who we are and how to contact us.

Who we are

Eliem Therapeutics (UK) Limited is the Controller (for the purposes of the UK GDPR) of your Personal Data (referred to as either “Eliem Therapeutics”, “we”, “us” or “our” in this Privacy Policy).

Our address is: 3rd Floor 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT.

How to contact us

You can contact us by email at GDPR@eliemtx.com or write to us at our trading address shown above.

Our Data Protection Officer

The UK GDPR requires us to appoint a “Data Protection Officer”, this is a person who is responsible for overseeing and advising us in relation to our compliance with the UK GDPR (including compliance with the practices described in this Privacy Policy). If you want to contact our Data Protection Officer directly, you can email: GDPR@eliemtx.com.

Your rights relating to your Personal Data.

Under certain circumstances, by by law, you have the right to:

Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact details shown above.

To ensure we are able to process your request as efficiently as possible, please include “Data Subject Request” in the subject line of any email you send us to exercise any such rights.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at GDPR@eliemtx.com or at our trading address shown above.

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the UK GDPR gives you the right to contact the Information Commissioner’s Office. You can contact them by calling 0303 123 1113 or by visiting their website https://ico.org.uk/

What Personal Data we collect.

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.

Category of Personal Data collected	What this means
Contact Data	•Your full name. • Your email address. • Any Personal Data you provide in the email you send us.
Technical Data	Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Aggregated Data

We also create, use and share “Aggregated Data” such as statistical or demographic data for any purpose based on use of the Site.

This Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the UK GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

No Special Categories of Personal Data

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Please do not provide us with any such data types.

How we use your Personal Data and why.

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

What is our “legal basis” for processing your Personal Data?

In respect of each of the purposes for which we use your Personal Data, the UK GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.

Purpose	Category(ies) of Personal Data involved	Why do we do this	Our legal basis for this use of data
Troubleshooting and Security	• Contact Data • Technical Data	To track issues that might be occurring on our systems. To keep our website, our services and associated systems operational and secure.	Legitimate Interests. It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services. We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.
Dealing with your contacts with us	• Contact Data • Technical Data	To deal with any contact you might make with us by email or post, as well as any issues arising from such contact (including replying to you).	Legitimate Interests. Compliance with Law.
Compliance with Law	• Contact Data • Technical Data	We may Process your Personal Data (including sharing it with competent authorities or regulators, and/or our advisers (see below) where necessary to comply with legal and regulatory requirements, and protect against fraud, illegal activity, and claims and other liabilities.	Compliance with Law.

What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).

In this case, we may have to stop you using our Site but we will notify you if this is the case at the time.

How we use cookies & other tracking or profiling technologies.

Cookies.

What are cookies?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies:

first party cookies, served directly by us to your computer or mobile device; and
third party cookies, which are served by our partners or service providers on our Site.

Cookies we use

Our Site uses the following type of cookies for the purposes set out below:

Type of cookie	Purpose
Essential Cookies	These cookies are essential to provide you with the core services available on our Site, and to enable you to use some of the Site’s features. Such core functionality includes security, network management, and accessibility. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies as described above.
Analytics and Performance Cookies	These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of current active users of our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies You can find out more about how Google protects your data here: https://www.google.com/analytics/learn/privacy.html.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help”, “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

Further 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 and www.youronlinechoices.com.uk.

You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en-GB

Who we share your Personal Data with.

The table below describes who we share your Personal Data with, what we share and why we share it.

Recipients	Category(ies) of Personal Data we share.	Why we share it
Our Affiliates	• Contact Data	Our affiliates help us provide our service and help manage our customer relationships (including providing customer support, customer liaison etc.).
Service Providers	• Contact Data • Technical Data	Our service providers provide us with IT and system administration services.
Professional advisers	• Contact Data	Our lawyers, bankers, auditors and insurers and other advisers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities	• Contact Data	Authorities may require reporting of processing activities in certain circumstances

Data transfers outside the UK.

We may share your Personal Data with third parties who are based outside the UK. In such circumstances, their processing of your Personal Data will involve a transfer of data to countries based outside of UK.

We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls required by the UK GDPR. So, whenever we transfer your Personal Data out of UK, we try to ensure a similar degree of protection is afforded to it by making sure at least one of the following mechanisms is implemented:

We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the UK Government from time to time.
We may transfer your Personal Data to countries that have not been deemed to provide an adequate level of protection for Personal Data by the UK Government – provided that, in these cases:
- we may use specific appropriate safeguards approved by the UK Government or the Information Commissioner’s Office, which are designed to give Personal Data the same protection it has in the UK (for example, requiring the recipient of Personal Data to enter into the relevant form of the so-called ‘Standard Contractual Clauses’ issued or approved from time to time); or
- in very limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

How we keep your Personal Data secure.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

How long we store your Personal Data.

We are committed to only keeping your Personal Data for so long as we reasonably need to use it for the purposes set out above. This general rule applies unless a longer retention period is required by law (for example for regulatory purposes).

Our policy on children.

Neither this Site, nor our products or services, is intended for children below 16 and we do not knowingly collect data relating to such children.

Third party links.

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.

ELIEM THERAPEUTICS (UK) LIMITED

LAST UPDATED: March 24, 2021