argenx BV (argenx) is conducting the MyRealWorld MG observational study (the study).The research portal enables users to access the aggregated observational results of the study.argenx is using the services of Vitaccess Limited (Vitaccess, we or us) to provide the technology for the research portal, and to manage the research portal and the associated study data.
In providing these services to argenx, Vitaccess may collect and use personal data of users on behalf of argenx. For data protection purposes, this means that argenx is the controller of user data, and Vitaccess is the processor.
This notice provides information to individual users of the research portal (you) about how and why we use your personal data in relation to your use of the research portal.
We may update this notice from time to time. It was last updated on [6 November 2020].
The remainder of this notice is set out in the following sections:
Vitaccess Limited is a company registered in England and Wales with company number 10642948. We act as a processor on behalf of argenx in our collection and use of your personal data for the purposes of the research portal, meaning that we act on argenx's instructions. In limited circumstances, we may act as a controller and ourselves determine how your personal data is used — see section 3.4 of this notice.
Vitaccess processes your personal data within the UK (although may transfer it to other countries in accordance with section 5 of this notice).
We have appointed a data protection officer, who is responsible for overseeing use of personal data by Vitaccess. Vitaccess (on behalf of argenx) acts as a primary contact for you in relation to use of your data for the research portal. Contact details are as follows.
Data protection officer
Vitaccess Limited
Address: 2nd Floor, Nucleus House, 2 Lower Mortlake Road, Richmond, UK, TW9 2JA
Email:dpo@vitaccess.com
argenx BV is a company incorporated under the laws of Belgium. argenx acts as a controller for the purposes of data protection laws, meaning that it determines how and why your data is to be collected and used by Vitaccess, and instructs Vitaccess accordingly.
[argenx has appointed a data protection officer, who is responsible for overseeing use of personal data by argenx]. Contact details for argenx are as follows.
argenx BV
Address: Industriepark — Zwijnaarde, Belgium
Email:DPO@argenx.com
Individual users may be granted access to the research portal by argenx (or by Vitaccess on behalf of argenx). In order to register for access, we will ask you to set up a username (generally your email address) and a password.
These details are used by us (on behalf of argenx) to manage your access to and use of the research portal. This may include sending you service updates by email.
The legal basis under data protection law for using your personal data is argenx's legitimate interests in giving you access to the research portal.
Information about your use of the research portal
We may also collect certain information about your use of the research portal, including the following:
We use this information (on behalf of argenx) to improve the research portal and its content (for example to expand areas that are most used, or to stop supporting those that are unused). We do not seek to identify you as an individual user for this purpose.
We may also use information about your use of the research portal to check you are using it appropriately and in accordance with our terms of use — see also sections 3.3 and 3.4 below.
[We seek your consent to the use of cookies to collect this information. ][Other than these specific consents, the legal basis under data protection law for using your personal data is argenx's or Vitaccess's legitimate interests in carrying out these activities.]
Your personal data may also be used by argenx or by us (on behalf of argenx):
The legal bases for these uses are, as appropriate, argenx's legitimate interests in the relevant activity, or as needed to comply with a legal obligation.
Vitaccess may, in limited circumstances, use your personal data as a controller for our own business purposes. These purposes include:
We may also conduct analysis of use of our technology (for example how the research portal is used), though we seek to anonymise the relevant data before conducting this analysis.
The legal bases for these uses are, as appropriate, our legitimate interests in the relevant activity, or as needed to comply with a legal obligation.
We do not collect or use sensitive categories of data as part of the activities described above (for example, information about health, racial or ethnic origin, or criminal convictions). If any such data becomes relevant (for example if you provide us with information about any special needs which you have in accessing the research portal), Vitaccess and argenx will assess the use of this data and, where appropriate, provide you with additional information about how we may use such data.
As argenx is the controller of your personal data in relation to our activities, it will have access, where required, to all personal data about you which Vitaccess collects and processes on its behalf. You should contact argenx to discuss any use of your data by it separate to the activities with which Vitaccess is involved.
Our technology service providers may handle your data. They act as sub-processors on behalf of argenx (but appointed by us), meaning that both argenx and we have responsibilities for their processing of your data. Our providers (as at the date of this notice) include:
We may share your data with legal authorities or regulatory bodies, where required or permitted by law, or where otherwise instructed by argenx.
The legal bases for such data sharing are, as appropriate, argenx's or our (or the recipient's) legitimate interests in the relevant activity, or compliance with a legal obligation.
Your data may be transferred to different countries to that in which you (or the organisation which you represent) are based. This includes:
We will retain your personal data for as long as we are instructed by argenx to do so for the relevant purposes specified above. Further information about retention periods is available on request.
You will have a username and password to access the research portal. We recommend you use a strong password of at least eight characters, including one upper and one lower case letter, and one number. You should not share your individual login details with any other person.
If you would like any further information about our information security measures, please contact us.
In accordance with data protection laws, you have a right:
Note that there are certain limitations and exemptions to these rights which may be applied depending on the circumstances.
Please contact Vitaccess (see contact details at section 2 above) to make requests to exercise these rights (specifying what you are requesting), or if you would like further information about them.