Privacy Policy – Effective January 19, 2023
Syros Pharmaceuticals, Inc. (“Syros”) recognizes the importance of protecting the privacy of information we may receive from visitors to our websites (the “website(s)” or the “site(s)”), and from individuals who interact with us in other ways. This Privacy Policy provides information about how Syros and its affiliates collect, use, share and safeguard information relating to individuals (“Personal Information”), and information about your rights and choices regarding our processing of your Personal Information. Please review this document carefully, as our processing of your Personal Information is subject to this Privacy Policy. A reference to “Syros “we,” “us,” or “our” is a reference to Syros and any relevant affiliate involved in the Personal Information processing activity.
Syros Pharmaceuticals, Inc., located at 35 CambridgePark Drive, Cambridge, MA 02140 USA, is the controller of your Personal Information as described in this Privacy Policy, unless specified otherwise.
Information We Collect/Information We Collect Automatically
Information Provided by You
We collect Personal Information you choose to provide to us, such as your name, address, telephone number or email address, through registrations, applications, surveys, support or information requests, or other data capturing processes. This includes Personal Information you send to us when (i) you contact Syros with your questions or comments through the Contact page on this website, (ii) you complete a sign-up form to learn more about a clinical trial or medical condition for which Syros is developing a treatment, or (iii) you provide Personal Information to us for another purpose. We may combine information we have about you with information obtained from public sources. Please note that if you provide Personal Information to Syros through a sign-up form and indicate that you wish to learn more about a clinical trial, Syros intends to share this information with clinical trial sites conducting trials so that they may contact you about the possibility of your enrolling in one or more trials. Healthcare professionals may choose to provide us with information relating to their specialties, and professional status and affiliations.
If you submit any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Information Collected from Website Use & Navigation
We collect information when you use and navigate the sites or interact with our emails, such as the URL of the site you came from, the browser software you use, your Internet Protocol (IP) address, date/time of access, data transferred, pages visited, amount of time you spend on the sites, information about transactions conducted on the sites, and other “clickstream” data. This data is generated and collected automatically, as part of the standard operation of the sites.
To make the sites work properly, we sometimes place small data files called cookies on your device. We use cookies, web beacons, tracking pixels, and other technologies to save your preferences, improve your site experience, and collect information when you use and navigate our sites or interact with emails from us. Tracking pixels are transparent graphic images, sometimes called web beacons or tracking beacons, that are placed on a web page or in an email to indicate that the page or email has been viewed. Pixels collect information about your browser or device and can also set cookies. If you access the sites using a mobile device, the device ID or IP address may be recorded and used for purposes similar to those of cookies.
Our sites use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics may collect information about your use of the sites, including your IP address. Google uses cookies to provide information about visits to our sites, including number of visitors, the websites from which visitors have navigated to our sites, and the pages on our sites to which visitors navigate. More information on Google Analytics can be found at the following link: www.google.com/policies/privacy/partners/
Our sites may use social media platform features, such as LinkedIn and the Facebook “like” button, the “Tweet” button and other sharing widgets. These features, which are either hosted by the respective social media network or hosted directly on our sites, allow you to post information to your third-party social media profile page and share it with others in your network. When you click through social media features from particular websites (including our sites), the social media network may receive information showing the websites you have visited. If you are logged in to your social media account, the social media network can link your visit to our sites and other websites with your social media profile, and may deliver advertisements or promotions about our products or services tailored to your interests. Your interactions with social media features are governed by the privacy policies of the companies providing these features.
When you visit the sites or interact with us in other ways, you can refuse to supply Personal Information. However, this may prevent you from engaging in certain site-related or other activities. By interacting with the sites or otherwise providing us with your Personal Information, you agree that we may collect, use, share and/or transfer that information in accordance with the terms and conditions of this Privacy Policy, subject to your rights and our obligations under applicable law.
Use of Information
This section describes the purposes for which Syros uses the Personal Information we collect. Please note that there may be other uses, which we would describe to you when we collect the information.
To contract with you
We may use the information you provide us to help us fulfill a contract with you, when you use our sites under the applicable Terms of Use, and for other contractual purposes. We may also use this information to enforce our rights arising from such contracts.
Our legitimate business interests
We process your Personal Information to pursue our legitimate business interests, including to:
- understand you and your preferences to enhance your experience and enjoyment using our sites;
- operate, maintain, and improve the content, design and navigation of our sites;
- respond to comments and questions, provide requested services and information, and otherwise communicate with you;
- develop and deliver our products and services;
- comply with regulatory monitoring and reporting obligations;
- send you information about our clinical trials, programs, offerings and company developments; and
- study website traffic patterns, detect and correct technical errors, and protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
To the extent permitted by applicable law, we may combine the various types of data we collect. We use this combined information to identify, update, expand, and analyze business opportunities and create tailored advertising. Such analysis may be conducted through third party services, using anonymous data and aggregate statistics generated by our information collection. We may use aggregate and/or de-identified data about visitors to our website for various business purposes, including development and improvement activities.
Consent
We may use your Personal Information when we have your consent to do so, where required or permitted under applicable law. If we are using your Personal Information on the basis of consent, you may withdraw your consent at any time (which will not affect the lawfulness of the processing before consent was withdrawn, or as otherwise agreed in writing) by contacting us at dataprotection@syros.com.
Compliance with Legal Obligations
We reserve the right to use your Personal Information (i) as required by law, court order, legal process or government or regulatory requirement; (ii) to respond to a request from public or government authorities; or (iii) to protect the safety, rights, or property of the public or Syros.
Sharing/Transferring Personal Information
In general, we may share and/or transfer your Personal Information to affiliates, agents, vendors or service providers who assist us in the process of providing products or services to you, or otherwise perform functions on our behalf. Third party service providers may use Personal Information we provide to them only as instructed by Syros. We will not rent, sell or otherwise transfer your Personal Information to a third party for monetary consideration. We reserve the right to disclose Personal Information to third parties where we believe in good faith that disclosure is required to comply with our legal obligations under applicable laws, to cooperate with regulators or law enforcement authorities, to comply with a judicial proceeding or legal process, or to protect the safety, rights, or property of our customers, the public, or Syros. If we sell or transfer a business unit or asset to another company, we may share or transfer your Personal Information pursuant to the terms of the transaction. In addition, we may disclose information about you to a third party at your request, or if you consent to the disclosure. We may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose.
Your Privacy Choices
You may update your Personal Information and your preferences, or request that we delete your Personal Information, by contacting us at dataprotection@syros.com. Our response to such requests will be limited to information under our direct control. We will respond to your request consistent with applicable law. Please note that we may need to retain certain Personal Information for recordkeeping purposes and/or to fulfill any pending request.
You may update your communications preferences or unsubscribe from email alerts or other communications at any time by contacting us at info@syros.com. We will comply with these requests unless such communications are required by law or contract, or do not require your consent under applicable laws.
Updates to Our Privacy Policy/Notification of Changes
Syros is continually improving and adding new functionality and features to our sites. Because of these ongoing improvements, changes in the law and the changing nature of technology, our data practices will change from time to time. Accordingly, we reserve the right to update or modify this policy at any time and from time to time without prior notice. If and when our data practices change, Syros will post the revised policy on our sites. Such changes to the Privacy Policy will become effective when posted. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you. Your continued use of the site after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy. We encourage you to check this page frequently to obtain the latest information on our privacy practices.
Children’s Privacy
We are committed to protecting the privacy of children and do not knowingly collect Personal Information from children under the age of 18. You should be aware that this website is not intended for, or designed to attract, children under the age of 18. No information should be submitted to Syros through this website by visitors who are less than 18 years of age.
Security
Please note that any information you send to Syros via email, in a sign-up form or via the Internet is not completely secure. We take reasonable steps to protect the Personal Information provided via our sites from loss, misuse and unauthorized access or disclosure, however, no Internet or e-mail transmission is ever fully secure or error free. Due to the nature of the Internet, there is a possibility that unsecured (unencrypted) email or Internet transmissions could be intercepted and read by third parties. Syros assumes no responsibility for interception of confidential information or Personal Information (including in a resume or CV or a sign-up form) that you send in an unsecured (unencrypted) email message or other Internet transmission to and from this website. Therefore, you should take special care in deciding what information you send to us via e-mail, in a sign-up form or via other Internet transmission. DO NOT SEND INFORMATION RELATING TO YOUR MEDICAL CONDITIONS OR THOSE OF A FAMILY MEMBER OR ANY OTHER SPECIFIC PERSONAL HEALTH INFORMATION VIA OUR WEBSITES, AS SYROS CANNOT BE RESPONSIBLE FOR PERSONAL HEALTH INFORMATION SENT THROUGH OUR WEBSITES. Please keep this in mind when disclosing any Personal Information to Syros via the Internet.
Data Retention and Access
We retain Personal Information or as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Policy. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is an applicable legal obligation; or (iii) whether retention is advisable to enforce our agreements, satisfy applicable statutes of limitations, resolve disputes, or manage litigation or regulatory investigations.
Links to Third Party Sites
This Privacy Policy applies only to websites owned or controlled by Syros. Our websites may contain links to other sites that are owned or controlled by third parties. Please be aware that we are not responsible for the privacy policies of such other sites or how these sites operate or treat your Personal Information. We encourage you to be aware of this when you leave our sites and to read the privacy policies and terms of use associated with each of these third party websites that collect personally identifiable information.
International Data Transfers and Processing
Any Personal Information you provide to Syros, and that Syros shares with affiliates, agents, vendors and service providers, may be stored and processed, transferred between and accessed from the United States and other countries, which may not guarantee the same level of protection of Personal Information as the country in which you reside. However, Syros will handle Personal Information in accordance with this Privacy Policy, and in compliance with applicable law.
Location-Specific Policies
Information for European, UK and Swiss Residents
If you are in the European Economic Area, United Kingdom, or Switzerland, your Personal Information may be protected by the European Union General Data Protection Regulation, United Kingdom Data Protection Act, or the Swiss Federal Act on Data Protection (collectively, “European Privacy Laws”). If your Personal Information is protected by the European Privacy Laws, you are entitled to certain rights related to your Personal Information. You have the right to access the Personal Information we have collected about you, the right to correct any inaccurate Personal Information we may have collected about you, and the right to supplement any incomplete Personal Information we may have collected from you. In certain circumstances, you have the right to the deletion or removal of your Personal Information, the right to restrict the processing of your Personal Information, the right to obtain and transmit your Personal Information to a third party, and the right to object to the way your Personal Information is being used (including when your Personal Information is processed for direct marketing purposes, or when your Personal Information is processed based upon our legitimate interests).
If you wish to exercise these data privacy rights, or if you have questions or concerns about how we use your Personal Information, please contact us at dataprotection@syros.com. and we will make efforts to respond to and/or resolve any issues consistent with applicable law. For your protection, when you seek to exercise the rights described above, it will be necessary for us to verify your identity or authority to make the request and confirm that the Personal Information relates to you.
If we are using your Personal Information based on your consent, you may withdraw this consent at any time. Your withdrawal of consent does not impact the lawfulness of our processing up to the point of consent withdrawal, or as otherwise agreed in writing.
Please note that there are exceptions to the various rights listed above. As an example, in the context of a deletion request, in certain circumstances we may have a legal obligation to retain some of your Personal Information.
Our Data Protection Representative for purposes of compliance with the European Privacy Laws is DataRep. If you want to raise a question or concern with Syros or otherwise exercise your rights with respect to your Personal Information, you may contact DataRep by e-mail at datarequest@datarep.com, or by mail at 72 rue de Lessard, Rouen, 76100, France, and refer to Syros in the subject line.
If you have a data privacy or data use concern that you feel has not been fully addressed, you have the right to lodge a complaint regarding use of your data with the applicable data protection authority. Here is a list of the data protection regulatory authorities: https://edpb.europa.eu/about-edpb/board/members_en.
Other Terms and Conditions
Your access to and use of this website is subject to the Terms of Use described elsewhere on this website.
Questions About Our Privacy Policy
If you have any questions about this Privacy Policy or concerns about the way Syros processes your Personal Information, or require assistance in managing your privacy choices, please contact us.
Contact Us
Syros Pharmaceuticals, Inc.
35 CambridgePark Drive, 4th Floor, Cambridge, MA 02140
Attn: Corporate Communications
info@syros.com
Tel: 617-744-1300