Privacy & Cookie Policy

01Who we are

This Privacy & Cookie Policy explains how Bionesty Ltd, trading as Bionabu (“Bionabu”, “we”, “us”, “our”), collects and uses personal data, and how we use cookies, when you visit www.bionabu.com (the “website”), complete our self-check, request a walkthrough, or otherwise contact us.

Bionabu develops software for clinical research teams, including Vera Deviate™, for protocol deviation management, and Vera Simulate™, a protocol stress test before first patient in, together with role-based training through Vera Academy.

We are the controller of the personal data described in this policy.

Company

Bionesty Ltd (trading as Bionabu)

Company number

11083899, registered in England and Wales

Registered office

483 Green Lanes, London, England, N13 4BS

ICO registration

ZB236813

Data protection lead

Ina Burgstaller, ina@bionabu.com

Privacy enquiries

privacy@bionabu.com

02The law that applies

We process personal data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR) for marketing and cookies, and, where we process data of visitors in the European Economic Area (EEA), the EU General Data Protection Regulation (EU GDPR).

03Who this website is for

Our website and services are intended for professionals working in clinical research and are not directed at anyone under 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact privacy@bionabu.com and we will delete it.

04The personal data we collect

Data you give us

• Identity and contact details: name, email address, phone number (if provided), job title, organisation and role (for example sponsor, CRO or site).
• Enquiry details: the information you enter in our contact or walkthrough form, such as how your study is run and which sources hold your deviations.
• Self-check responses: your answers to our delegated deviation oversight self-check stay in your browser. We receive them, with your score and email address, only if you tick the box to share them with us. If you ask for a copy, it opens as an email in your own email app; we do not send it.
• Communications: emails and messages you send us, and notes from calls you book with us.
• Marketing preferences: whether you have consented to receive marketing from us, and when and how you gave or withdrew that consent.

Data collected automatically

• Device and technical data: IP address, browser type and version, operating system and device type.
• Approximate location derived from your IP address (country or city level).
• Usage data: pages viewed, referring website and time on the website, collected through Squarespace analytics and, where you consent, analytics cookies (see section 8).

05Why we use your data and our lawful basis

Where we rely on legitimate interests, we have balanced our interests against your rights. You can ask us for more detail on this balancing at privacy@bionabu.com.

06Direct marketing

We only send marketing emails if you have opted in by ticking an unticked marketing consent box on our forms. Agreeing to marketing is never a condition of using the self-check or booking a walkthrough.

Marketing may include occasional emails about Vera Deviate, Vera Simulate, Vera Academy and related clinical research resources. You can withdraw your consent at any time by clicking the unsubscribe link in any email or by contacting privacy@bionabu.com. We will act on your request promptly. We keep a record of when, where and how you gave or withdrew consent.

07Who we share your data with

We do not sell your personal data. We share it only with:

• Service providers who process data on our behalf under contract, such as website hosting, form and email tools, scheduling, analytics and IT providers. They may only use your data to provide their services to us.
• Professional advisers, such as lawyers, accountants and insurers, where necessary.
• Authorities, regulators or courts where we are required by law.
• A buyer or successor if our business is sold or restructured, subject to equivalent protection of your data.

Our current service providers are:

08Cookies

Our website runs on Squarespace and we use Cookiebot to manage cookie consent. We use:

• Strictly necessary cookies, which the website needs to work and stay secure (for example to remember your cookie choice and protect forms from spam). These are always active and do not require consent.
• Non-essential cookies, such as analytics cookies that help us understand how visitors use the website. These are only set after you give consent.

When you first visit, our cookie banner lets you accept all cookies, reject all non-essential cookies, or choose individual categories. Rejecting non-essential cookies does not affect your ability to use the website. You can change or withdraw your consent at any time using the Cookie settings link at the bottom of every page, or by clearing cookies in your browser.

The full list of the cookies we use, with their provider, purpose and duration, is shown below. Cookiebot generates it and keeps it up to date automatically.

09International transfers

We are based in the United Kingdom, which is outside the EEA. Personal data of EEA visitors is transferred to the UK on the basis of the European Commission adequacy decision for the UK.

Some of our service providers store or access data outside the UK and EEA, including in the United States. Where this happens, we make sure appropriate safeguards are in place, such as:

• the UK–US data bridge (UK Extension to the EU–US Data Privacy Framework) or the EU–US Data Privacy Framework, where the provider is certified; or
• the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or the EU Standard Contractual Clauses.

You can request details of the safeguards we use by contacting privacy@bionabu.com.

10How long we keep your data

When data is no longer needed, we delete or anonymise it securely.

11How we protect your data

We use appropriate technical and organisational measures to protect personal data, including encryption in transit (HTTPS), encrypted storage, two-factor login on the tools we use, and access limited to named staff. No method of transmission over the internet is completely secure, but we work to protect your data and review our measures regularly.

12Data breaches

If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner’s Office (ICO) within 72 hours of becoming aware of it, where required. If the breach is likely to result in a high risk to you, we will inform you without undue delay by email, and, where we cannot reach you directly, by a notice on our website.

13Your rights

Under data protection law you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased in certain circumstances;
• restrict how we use your data in certain circumstances;
• object to processing based on our legitimate interests, and to object at any time to direct marketing;
• receive your data in a portable format, where processing is based on consent or contract;
• withdraw your consent at any time, without affecting processing carried out before withdrawal.

To exercise any of these rights, email privacy@bionabu.com. We will respond within one month. We may need to confirm your identity before acting on your request. There is normally no charge.

14Complaints

If you have a concern, please contact us first at privacy@bionabu.com so we can try to resolve it. You also have the right to complain to the UK supervisory authority:

Authority

Information Commissioner’s Office (ICO)

Address

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Website

ico.org.uk

Helpline

0303 123 1113

If you are in the EEA, you can also complain to the data protection authority in your country.

15Changes to this policy

We may update this policy from time to time. The latest version will always be on this page with its “Last updated” date. If we make material changes, we will tell people whose email address we hold before the changes take effect. Where a change requires your consent, we will ask for it separately.

16Contact us

Bionesty Ltd (trading as Bionabu), 483 Green Lanes, London, England, N13 4BS
Email: privacy@bionabu.com