Last updated October 20, 2023
At Zenas BioPharma, Inc. (“Zenas,” “we,” “us” or “our”) we take your privacy and the security of your information very seriously.
This Privacy Policy (“Policy”) covers this Zenas owned and operated website (www.zenasbio.com), other sites that link to this Policy (“Site”or “Sites”), and any services offered via the Sites, as well as through any of our offline services that reference this Policy (collectively, “Services”). Services may include, for example, third parties such as employment recruiting providers that collect personal data on our behalf as data processors.
If you have any questions regarding this Policy, please contact us by emailing privacy@zenasbio.com.
The Policy describes the types of information we gather from individual users (“you” or “users”) interacting with our Site and how we use, transfer, and secure such information. Your access to our Site and use of any Services indicates your acceptance of this Policy. If you do not agree to the terms of this Policy, please do not use the Site, or related Services.
Personal Information We Collect
Data You Choose to Provide
“Personal Information” is information that can be used to identify you (such as name and contact information). Personal Information that you may voluntarily provide through our Sites or otherwise share with us includes:
- Personal and Business Contact Information, such as your first name, last name, postal address, email address, telephone number, job title, and employer name;
- Professional Credentials, such as educational and work history, institutional affiliations and other information of the type that would be included on a resume or curriculum vitae;
- Profile Information, such as your username and password, industry, interests and references;
- Feedback and Correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with the Sites, receive customer support or otherwise correspond with us;
- Transaction Information, such as details about programs, events or other activities you register for through the Sites;
- Usage Information, such as information about how you use the Sites and interact with us; and
- Marketing Information, such as your preferences for receiving marketing communications.
Information Automatically Collected
We may automatically log information about you and your computer or mobile device when you access our Sites. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Sites, pages you viewed, how long you spent on a page, and access times and information about your use of, and actions on, our Sites. We collect this information about you using cookies. Please refer to the section below on cookies for more details.
Use of “Cookies” and Similar Technologies
What are cookies?
Cookies are alphanumeric identifiers that are transferred to your computer’s hard drive through your web browser to help us identify you when you come to our Site. Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a better experience when you use our Site and allows us to improve our site.
You have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you may be unable to use those aspects of our Sites that require registration to participate. You can learn about cookies and how they work at www.allaboutcookies.org.
You can disable cookies through your browser settings. Doing so, however, may disable certain features on our Sites. You can opt out from third-party cookies that are used for advertising purposes on the NAI website at www.networkadvertising.org/managing/optout.asp. If you are accessing this site from the EU or UK, your consent to the placement of cookies indicates your consent to the transfer of data collected by such cookies to third countries that may not have a level of data protection comparable to the EU or UK. You can always withdraw your consent by adjusting your preferences. Depending on which Site you visit, we may use the following categories of cookies:
Strictly Necessary Cookies. These cookies are required for the operation of our Site. These cookies cannot be switched off. You can set your browser to block these cookies, but as a result, some parts of our Site will not work as designed.
Analytics and Performance Cookies. Analytical cookies allow us to analyze traffic to our Site and how our Site is used. For example, we may use analytics cookies to count the number of visitors and sources of web traffic so we can see how users move around our Site. This helps us improve the way our Site works, for example, by ensuring that users can easily find information for which they are looking.
This Website uses Google Analytics to collect information about you and your browsing behaviors. If you would like to opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout/.
Functional Cookies. These cookies allow our Sites to remember choices you make when you use our Sites. The purpose of these cookies is to provide you with a more personal experience and to avoid you from having to re-select your preferences every time you visit our Sites.
Targeting Cookies. These cookies may be set through our Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store directly Personal Data but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
We may also use cookies, pixels, beacons, or other web tracking technologies to track the amount of time spent on our Sites and whether certain content, such as a video was viewed. We may work with a trusted third party to collect and process this information for us, based on our instructions and in compliance with this Policy.
Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.
How We Use Your Personal Data
To provide you with information and administer our Site
If you use our Site or provide us with Personal Data to participate in our programs, events or other activities, we may use your Personal Data to:
- operate, maintain, administer and improve the Site;
- process and manage registrations you make through the Site;
- provide information regarding our programs, events, or activities for which you may have registered;
- send you technical notices, updates, security alerts, and support and administrative messages;
- process and manage applications for employment that you make through the Site;
- better understand your needs and interests, and personalize your experience with the Sites;
- provide support and maintenance for the Sites and our services; and
- respond to your service-related requests, questions and feedback.
To communicate with you
If you request information from us, we may send you commercial or marketing communications as permitted by applicable law. You may opt-out of such communications pursuant to the directions in each communication or contacting us at privacy@zenasbio.com.
To comply with legal obligations
We may use your Personal Data as necessary or appropriate to comply with applicable laws, lawful requests and legal processes, such as to respond to requests from government authorities.
With your consent
We may use or share your Personal Data with your consent, such as to send you marketing communications, to post testimonials or images to our Site, or if you instruct us to take specific actions with regard to your Personal Data.
For compliance, fraud prevention and safety
We use your Personal Data as necessary or appropriate to (i) enforce the terms and conditions that govern use of our Sites; (ii) protect our rights, privacy, safety or property; and (iii) protect, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity.
Legal Bases for Processing
If you reside in the United Kingdom (“UK”), the European Economic Area (“EEA”) or Switzerland, we are required to inform you of the legal bases of our processing of your personal data on our Sites, which are described in the table below.
| Processing purpose | Legal basis |
| To provide services | Processing is necessary to provide services to you or to take steps that you request prior to providing those services. |
| To communicate with you For compliance, fraud prevention and safetypurposes To create anonymous analytics | These processing activities are based on our legitimate interests. We consider and balance potential impact on your rights and do not process your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). |
| To comply with law | Processing is necessary to comply with our legal obligations. |
| With your consent | Processing is based on your consent. Where we rely on consent, you have the right to withdraw it at any time. |
Sharing of Personal Data with Third Parties
Zenas does not sell your Personal Data. We may transfer Personal Data to third parties for the purpose of providing Services. We may disclose Personal Data to our affiliates or third-party service providers to provide you with Services. These third-party service providers are not authorized to retain, share, store or use the Personal Data for any purposes other than to provide the services they have been hired to provide.
We may also elect to transfer your Personal Data to third parties under special circumstances, including: (i) to comply with a legal requirement, judicial proceeding, court order, or legal process served on us; (ii) to investigate a possible crime, such as fraud or identity theft; (iii) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of Zenas; (iv) when we believe it is necessary to protect the rights, property, or safety of Zenas or other persons, or (v) as otherwise required or permitted by law.
Some links on our Site may redirect you to third-party websites and services that we do not operate. The privacy practices of these websites and services will be governed by such website’s own policies. We make no representation or warranty as to the privacy policies of any third parties, including the providers of third-party applications. If you are submitting information to any such third party through our Site or Services, you should review and understand that party’s applicable policies, including their privacy policy, before providing your information to the third party.
Transfer of Information
Zenas is based in the United States and has affiliates and service providers in other countries. Personal Data you provide to us or that is collected via our Sites may be transferred to the United States or other locations outside of your state, province or country where privacy laws may not be as protective as those in your country. We will process and transfer your Personal Data in accordance with applicable law and this Policy regardless of where your Personal Data is stored or accessed. Our third-party service providers are contractually bound to treat Personal Data in a manner that is consistent with this Notice and applicable data protection laws.
If you reside in the EEA, Switzerland or the United Kingdom, please note that Zenas BioPharma is certified to the EU-US and Swiss-US Data Privacy Framework (“DPF”), as well as the UK Extension to the EU-US DPF. The DPF has been determined by the European Commission to provide an adequate level of protection concerning the transfer of your Personal Information to the US and the processing by recipients in the US. You can find further information about our DPF Certification at https://www.dataprivacyframework.gov/s/participant-search.
Children and Privacy
We do not knowingly collect Personal Data from children in connection with the features of our Sites or Services. If we become aware that an individual under the age of 16 has provided Personal Data through our Sites or Services, we will immediately remove the individual’s Personal Data. We request that parents and guardians do not use the Site or email to provide us with any Personal Data concerning children.
How We Protect Your Personal Data
We take the security of your Personal Data seriously. We use reasonable administrative, physical, and technical safeguards to secure the Personal Data you share with us. Despite these safeguards, we cannot guarantee the security of your Personal Data.
Any email or other communication purporting to be from one of our websites asking you to provide sensitive information (including medical information) via email, should be treated as unauthorized and suspicious and should be reported to us immediately by emailing privacy@zenasbio.com.
Retention
We will only retain Personal Data for as long as is necessary to fulfill the purpose for which it was collected (or for any subsequent purpose that is compatible with the original purpose). This does not affect your right to request that we delete your Personal Data before the end of its retention period. We may archive Personal Data (which means storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures.
Changes to This Privacy Policy
Each time you use our Site or Services, the current version of the Policy will apply. We encourage you to periodically review this page for the latest information on our privacy practices. When we make any change to this Policy that has a significant impact on the privacy rights of users, we will indicate such on the main page of the Site.
Your Rights
If you reside in the United Kingdom, EEA or Switzerland, you may request that we take the following actions with regard to your Personal Data by contacting us at privacy@zenasbio.com:
- Access: Provide you with information about our processing of your Personal Data and give you access to your Personal Data.
- Correction: Update or correct inaccurate Personal Data.
- Deletion: Delete your Personal Data.
- Transfer: Transfer a machine-readable copy of your Personal Data to you or a third party of your choice.
- Restriction: Restrict the processing of your Personal Data.
- Objection: Object to our legitimate interest as the basis of our processing of your Personal Data.
If you reside in California, you or your authorized agent may request that we take the following actions with regard to your Personal Data by contacting us at privacy@zenasbio.com:
- Access: Disclose to you the categories of Personal Data we have collected, used or disclosed within the last 12 months, including Personal Data, if any, that we disclosed to third parties for marketing purposes.
- Deletion: Delete your Personal Data.
- Transfer: Transfer a copy of specific pieces of your Personal Data that we have collected or used within the last 12 months.
We may require additional information to verify and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will inform you of such decision, subject to legal restrictions.
If you no longer wish to receive promotional communications, you may opt out of receiving them by following the instructions included in each communication.
If you are a resident of the United Kingdom, EEA or Switzerland, you have the right to file a complaint concerning our processing of your Personal Data with your national (or in some countries, regional) data protection authority.
Contact Us
To contact us with questions or comments regarding this Policy or the information collection and dissemination practices of this Site, or to request this Policy in an alternative format due to a disability, please email us at privacy@zenasbio.com, or write to us at:
Zenas BioPharma, Inc.
Legal Department
1000 Winter Street
North Building Ste. 1200
Waltham, MA 02451
Any communications relating to clinical trials should be made through the communication channels described in the applicable informed consent, patient information sheet or other instructions provided to clinical trial participants.
If you reside in the UK, you can contact our UK representative by email at ukrepresentative@privacyminders.com.
If you reside in the EU, you can contact our EU representative by email at zenasbiopharma@isico-datenschutz.de.
You may also contact our Data Protection Officer by sending an email to privacy@zenasbio.com with the subject line “Data Protection Officer”.