Last Updated: February 24, 2025
Recursion Pharmaceuticals and its affiliates and subsidiaries (“Recursion”, “we”, “our”, and “us”) is committed to protecting and maintaining your privacy. This Privacy Notice (“Notice”) is designed to help you understand how we collect, use, and share your Personal Data. Recursion processes Personal Data in accordance with applicable national, provincial/state, and local laws and regulations.
This Notice applies to the processing of your Personal Data when:
Within the scope of this Notice, Recursion generally acts as a data controller for the Personal Data we process. This means that we decide how and why Personal Data is collected and further processed.
Recursion may have other unique privacy policies or notices that apply to certain specific situations. To the extent you were provided with a different privacy policy or notice and that policy or notice applies, those policies or notices will govern our interactions with you, not this one. For example, if you are a participant in a clinical study, clinical trial, or other health-related research, you should receive a separate privacy notice regarding the Personal Data we process for those purposes.
Please review this Notice carefully. To the extent permitted by applicable law, by providing us your Personal Data or otherwise interacting with us, you are agreeing to this Notice.
We may process your Personal Data when you visit our Website or communicate with us either online (such as by email or via our social media platform) or offline (such as by phone or to our physical address).
What types of data may we process?
Identity and contact information, such as:
Other personal information, such as:
Technical Information, such as:
Anonymized / Deidentified Data
Anonymized Data / De-identified Data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws.**
What types of data may we process?
What types of data may we process?
What types of data may we process?
What types of data may we process?
We may process your Personal Data when you act as a business partner, such as a vendor, supplier, distributor, retailer, or service provider, or are an employee, agent, or contractor of a business partner.
What types of data may we process?
Identity and contact information, such as:
Other personal information, such as:
Commercial and financial information, such as:
Anonymized / Deidentified Data
Anonymized Data / De-identified Data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws.**
What types of data may we process?
What types of data may we process?
What types of data may we process?
What types of data may we process?
We may process your Personal Data when you act as an existing or prospective clinical investigator or member of an investigation for a clinical study sponsored by us or conducted by us on behalf of a third party.
What types of data may we process?
Identity and contact information, such as:
Other personal information, such as:
Professional and educational information, such as:
Commercial and financial information, such as:
Interaction data, such as:
Anonymized / Deidentified Data
Anonymized Data/De-identified Data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws.**
What types of data may we process?
What types of data may we process?
What types of data may we process?
What types of data may we process?
We may process your Personal Data when you have been identified as a potential candidate for clinical studies sponsored by us or conducted by us on behalf of a third party.
What types of data may we process?
Identity and contact information, such as:
Other personal information, such as:
Information regarding your treatment, such as:
Anonymized / Deidentified Data
Anonymized Data/De-identified Data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws.**
What types of data may we process?
What types of data may we process?
What types of data may we process?
What types of data may we process?
We may process your Personal Data when you apply or are a candidate for employment or apprenticeship at Recursion.
What types of data may we process?
Identity and contact information, such as:
Other personal information, such as:
Professional and educational information, such as:
Anonymized / Deidentified Data
Anonymized Data / De-identified Data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws.**
What types of data may we process?
What types of data may we process?
What types of data may we process?
What types of data may we process?
**We will not attempt to re-identify you or anyone else from this Anonymized Data / De-identified Data, and if we disclose it to third parties, we will require that they commit to not attempting to re-identify you or anyone else from the Anonymized / De-identified Data. Anonymized Data / De-identified Data includes health information resulting from the removal of identifiers from protected health information required under the Health Insurance Portability and Accountability Act, 45 CFR § 164.514(b)(2). Please note that in the course of research, study doctors and authorized personnel may still have access to named subject records collected for such research.
***The legal bases relied upon by Recursion include those enumerated in Articles 6 and 9 of the GDPR, depending on the type of Personal Data.
****In limited circumstances, recipients may include: (1) in the event of a sale, assignment, or transfer, the buyer, assignee, or transferee; and (2) government or regulatory officials, law enforcement, courts, public authorities, or others when permitted by this Notice or required by law.
Combination of Data
We may combine information we collect, whether Personal Data or not, with Personal Data that we may obtain from third parties
Children’s Data
Recursion does not knowingly collect, maintain, disclose, or otherwise process Personal Data from minors below the age of 16 without the permission of such minor’s parents or legal guardians.
Marketing Uses, Cookies, and Other Activities
To the extent permitted by applicable law, including in accordance with your consent where required by applicable law, we may engage in the following activities:
Processing Using Website Tracking
We may use different service providers to help us understand how users engage with this and other of our Website. These service providers may track your activity on our Website (i.e., the pages you have seen and the links you have clicked on) and helps us measure how you interact with the content that we provide. This information is used to compile reports and to help us improve the Website. The reports we receive disclose website trends without identifying individual visitors.
Do-Not-Track Signals
Certain web browsers and other programs may transmit “opt-out” signals, also called a Global Privacy Control (or GPC) signal (we refer to these as “GPC Signals”), to websites with which the browser communicates. In most cases you will need to change your web browser’s settings or add an application to your web browser to enable your browser to send a GPC Signal. Recursion’s Website will recognize and apply the GPC Signal to inactivate targeting cookies, but will not apply the GPC Signal to functional, performance or strictly necessary cookies.
Third-Party Service Providers
Third-party service providers acting on our behalf must execute agreements including confidentiality requirements and will only process Personal Data as necessary to perform their functions in a manner consistent with this Notice, other applicable privacy policies, and as explicitly permitted or required by applicable laws, rules, and regulations. Our third-party service providers may be located in the United States and other jurisdictions.
Safeguarding Information
Consistent with applicable laws and requirements, Recursion has put in place physical, technical, and administrative safeguards to protect Personal Data from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure consistent with legal obligations and industry practices. However, as is the case with all websites, applications, products, and services, we unfortunately are not able to guarantee security for data collected through our Website.
Your Rights Regarding Your Personal Data
Please note that in many circumstances, we cannot effectively do business with you without processing some Personal Data about you (e.g., your contact information).
Under your jurisdiction’s data protection law, you may have one or more of the following rights with respect to some or all of your Personal Data:
To learn if you have the other above rights in the jurisdiction in which you live and to exercise any of these rights with respect to your Personal Data, please contact us at the email or phone number provided below. We will not discriminate against you for exercising any of the rights described above, although we may not be able to continue to provide you products and services and it may otherwise affect the way we are able to interact with you.
We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
In the event you wish to make a complaint about how we process your Personal Data, please contact us at the email address below and we will handle your request as soon as possible. Even if you make a complaint to us, you may always lodge a complaint with the relevant authority in your location.
Notice of Right to Opt Out of Sale/Sharing
Certain of Recursion’s practices may be considered the sale or sharing of Personal Data under applicable law. You may have the right to opt-out of the sale of Personal Data or opt-out of sharing of Personal Data for purposes of cross-context behavioral advertising (sometimes referred to as targeted advertising). To exercise these rights, please see the “Your Rights Regarding Your Personal Data” section above.
Automated Individual Decision-Making
If you are a clinical study candidate in a trial we sponsor, you will be assigned a unique patient identification number. This number may be used as part of an automatic process that randomly determines if you will receive the experimental drug product or treatment that is being evaluated in the trial. This type of automated decision-making is required in order to ensure that the trial is conducted in an ethical way, and in accordance with the pharmaceutical industry’s standards. For decisions that may seriously impact you, you have the “right not to be subject to automatic decision-making, including profiling.” But in those cases, we will always explain to you when we might do this, why it is happening, and the potential effect on you.
Transfer of Personal Data Across National Borders
Recursion operates in several countries, including the U.S. We, together with our affiliates, service providers and other third parties with whom we share Personal Data, operate globally. Please be aware that Personal Data we collect and process may be transferred and maintained outside your state, province, country, or other jurisdiction where the privacy laws may not be as protective as those in your location, including the United States. Recursion has put in place lawful transfer mechanisms and adequate safeguards, in accordance with applicable legal requirements, to protect your Personal Data. For example, if you are located in the European Economic Area (“EEA”), these transfer mechanisms include adequacy decisions and standard contractual clauses.
Adequacy Decisions: Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection under Article 45 GDPR (or equivalent decisions under other laws). We transfer your Personal Information as described under the heading ‘Categories of Personal Information and How We Collect It’ to certain jurisdictions that benefit from adequacy decisions, such as Canada. A list of jurisdictions for which the European Commission has issued an adequacy decision is available here.
Standard contractual clauses: For transfers from to countries not considered adequate by the European Commission, we have put in place adequate measures such as Standard Contractual Clauses to protect your Personal Information. The European Commission has approved contractual clauses under Article 46 GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses. We rely on standard contractual clauses to transfer Personal Information to certain affiliates and business partners in countries without an adequacy decision.
In certain situations, we rely on derogations provided for under the applicable law to transfer Personal Information to a third country.
How Long Your Personal Data Will Be Retained
We generally retain Personal Data no longer than needed for the specific business purpose or purposes for which it was collected. In some cases, we may be required to retain Personal Data for a longer period of time by law or for other necessary business purposes.
Changes to This Privacy Notice
We reserve the right to change this Notice from time to time. We will alert you when changes have been made by indicating the date this Notice was last updated as the date the Notice became effective or as otherwise may be required by law. It is recommended that you periodically revisit this Notice to learn of any changes.
If you have any questions or comments about this Notice or feel that we are not abiding by the terms of this Notice, please contact us in any of the following ways:
By e-mail: compliance@recursionpharma.com
By phone: 385-269-0203
By postal mail or courier:
Recursion Corporation
Attn: Compliance Department
41 S. Rio Grande Street
Salt Lake City, Utah 84101
European Union Representative. In the European Union, you can contact our representative VeraSafe using this contact form, https://www.verasafe.com/privacy-services/contact-article-27-representative/, or alternatively via mail or telephone at:
VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland
+420 228 881 031
United Kingdom Representative. In the United Kingdom, you can contact our representative VeraSafe using this contact form, https://www.verasafe.com/privacy-services/contact-article-27-representative/, or alternatively via mail or telephone at:
VeraSafe United Kingdom Ltd.
37 Albert Embankment
London
SE1 7TL
United Kingdom
+44 (20) 4532 2003
Data Protection Officer. We have appointed VeraSafe as our Data Protection Officer (DPO). While you may contact us directly, VeraSafe can also be contacted on matters related to the processing of Personal Data. VeraSafe’s contact details are:
VeraSafe LLC
100 M Street S.E., Suite 600
Washington, D.C. 20003 USA
Email: experts@verasafe.com
Web: https://www.verasafe.com/about-verasafe/contact-us/