LIDRISE Study Website – Privacy Policy

Our commitment to privacy

The LIDRISE Study website available at lidrise-study.com (the “Website”) is operated by Santen SAS, a company incorporated under the laws of France, with registered office at Tour W, 102 terrasse Boieldieu, 92085 Paris La Défense CEDEX, France (“Santen”, “we”, “our”).

The Website is developed and technically maintained by Tann Westlake Ltd, a UK-based service provider, acting as data processor on behalf of Santen. Santen acts as the data controller for personal data processed via the Website.

The Website is intended for individuals who wish to learn more about participation in the LIDRISE clinical study (“you”, “your” or “users”). It provides general information in plain language about the study, its purpose, what to expect, and how to find participating study centers. The Website does not collect health information or allow you to enroll directly in the study.

At Santen, we recognize the importance of, and are fully committed to protecting the privacy of personal data related to all individuals with whom we interact. This Policy is designed to assist you in making informed decisions when using our Website or interacting with us.

We encourage you to read this Policy carefully. By using the Website, you acknowledge that you have been informed about how and why personal data may be processed in connection with its operation, as described below.

Scope of this policy

This Policy applies to all visitors of the LIDRISE Study Website. It is intended for individuals seeking general information about the clinical study. The Website does not provide medical advice and is not designed for healthcare professionals in their professional capacity.

Personal data we collect

When you use the LIDRISE Study Website, very limited personal data may be processed. The Website does not provide account creation, subscription, or direct communication functionalities. We do not collect health-related information or allow you to enrol directly in the study.

No personal data is directly collected through forms, subscriptions, or account registrations. If you wish to contact a study site, you will do so directly via the contact details published on the Website, and such processing will be handled by the relevant study centre and not by Santen.

(a) Pre-screener inputs

The Website includes a simplified pre-screener questionnaire to help you understand whether you may be eligible to participate in the study. Your answers are processed in real time on your device to display information, but they are not stored, transmitted, or linked to your identity.

(b) Automatically collected technical data

Personal data may be collected automatically when you use our Website. This includes:

Technical logs and usage data, such as your IP address, browser type and version, operating system and platform, time zone setting, and general information about how you navigate the Website. This processing is limited and primarily used for security purposes. We use a privacy-first analytics/security tool (Fathom Analytics) that processes IP addresses only briefly for security (rate-limiting) before anonymising them; no cookies, fingerprinting, or persistent identifiers are used.
Cookies and similar technologies, limited to strictly necessary cookies that enable basic functionality such as remembering your language preference or storing your cookie consent choices. Further details are provided in our Cookie Policy.
Embedded external services, such as Google Maps. When you choose to view the interactive map, your browser connects directly to Google to display it; as a result, Google receives your IP address and device details. In our current implementation, the map does not set cookies or use device storage on this Website. Further details are provided in this Policy and in our Cookie Policy.
Geolocation (optional). If you choose “Use current location”, your browser may share your approximate location to display nearby centres. This permission is managed by your device or browser. Santen does not receive or store your location, and your choice does not create an account or profile on this Website.

Purpose of processing personal data

Santen may process limited personal data in connection with your use of the LIDRISE Study Website for the purposes set out below, in accordance with applicable data protection laws and this Policy. The Website does not provide registration, account creation, or study enrolment and does not collect health information.

To provide and operate the Website, including displaying study information in plain language and the “Find a Study Center” feature.
To ensure the security, availability and integrity of the Website (for example, detecting or preventing denial-of-service activity and abuse), which involves limited, time-bound technical processing such as brief IP handling by our analytics/security provider.
To offer optional embedded external services you choose to use (e.g., an interactive map to obtain directions). Where such services involve third-party processing or set non-essential cookies, this will be disclosed in our Cookie Policy and, where required, only activated with your consent.
To comply with legal obligations and to establish, exercise or defend legal claims, and to respond to data subject requests.
To provide real-time, client-side pre-screener functionality that helps you understand whether you may be eligible to participate in the study; your answers are used only to display information during your session and are not stored or transmitted.

We retain personal data only for as long as necessary for the purposes described above or as required by law. For example, security-related technical data processed for rate-limiting and abuse prevention is retained only for a short period; anonymised, aggregate usage metrics do not identify you. Where third-party services are involved (e.g., map providers), their retention practices are described in their own policies and referenced in our Cookie Policy.

Legal basis of processing

Santen processes personal data based on one or more of the following conditions:

Where the processing is necessary to provide you with the requested services offered through the Website (for example, delivering the pages you request, operating the client-side pre-screener during your session, and deploying strictly necessary cookies that enable basic functionality), including using your device’s geolocation solely to show nearby centres when you select that option;
Where the processing is necessary to ensure Santen’s compliance with a legal obligation e.g. to comply with applicable laws, regulatory requests or to establish, exercise or defend legal claims;
Where the processing is in Santen’s legitimate interest, for example where such processing is strictly necessary for the technical operation and security of the Website (including availability, abuse and DDoS prevention), limited and time-bound handling of IP addresses by our analytics/security provider for rate-limiting, and equivalent security-related processing carried out by our hosting infrastructure. We balance these interests against your rights and reasonable expectations.

Redirect to other web sites

From the Website, you may connect through links to third-party websites and, where enabled, view third-party embedded content (for example, an interactive map to obtain directions). Accessing such links or loading embedded content may result in those third parties processing your personal data (e.g., receiving your IP address, device details and, where applicable, setting cookies or similar technologies).

Santen does not control and is not responsible for third-party websites or services, their content, or their processing of personal data. Embedded content on this Website does not set cookies in our current implementation. When you view or interact with the map, your browser connects to Google and Google processes your data under its own privacy policy. We encourage you to read and be aware of the privacy policy, and all other policies, of each site you visit. Remember, the statements in this Policy apply solely to information collected by Santen on this Website and further details are set out in our Cookie Policy.

Disclosure of personal data

Personal data are not disseminated to unspecified recipients. Santen discloses your personal data to third party recipients on a need-to-know basis where this is reasonably permitted to pursue its legitimate business aims and as required by applicable law (for example, to our website developer/maintenance provider and hosting infrastructure, and to our privacy-first analytics/security provider for limited, time-bound security purposes). Where enabled, certain optional third-party services (such as an embedded interactive map) may receive your personal data directly when you choose to use them; in such cases those providers act as independent controllers for their own processing, as further described in our Cookie Policy.

For more information on Santen’s privacy practices, how we handle your personal data and the measures we take in order to disclose it lawfully and safely internally and externally with our affiliates, service providers and partners, please read our Santen Privacy Policy available on our corporate website here at https://www.santen.eu/dataprivacy.

Where disclosures involve recipients located outside your country (including outside the EEA/UK), we will ensure that appropriate safeguards are in place, such as adequacy decisions or standard contractual clauses, and we will monitor any changes to applicable transfer rules. Please note that contacting a study site using the contact details published on the Website occurs outside of this Website and will be handled by the relevant study center as a separate controller.

Automated decision making

Santen does not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you in connection with the Website. The pre-screener operates client-side to display information in real time based on your answers; responses are not stored or transmitted, and no eligibility decisions are made by the Website. Any determination about your participation in the study is made separately by study personnel in accordance with the study protocol.

Santen will not make any automated decisions about you that would affect your legal rights or similarly affect you as an individual or negatively affect your business or customer relationship with Santen.

You can always raise any concerns you may have in relation to our decision-making and processing at any time by contacting us at privacy-emea@santen.com.

Santen Email News & Updates

The Website does not offer registration, newsletters, or direct marketing communications. Santen does not collect contact details via this Website for promotional purposes and will not send you electronic communications through this Website. If this position changes in the future, any such communications would be sent only with your prior consent, which you may withdraw at any time as described in this Policy.

Your data protection rights

Under applicable laws and subject to any legal restrictions, you may have the right to request us to:

Provide you with further details on the processing of your personal information;
Provide you access to your personal data that we hold about you;
Update any inaccuracies in the personal information we hold that is demonstrated to be inaccurate or incomplete;
Delete any personal information that we no longer have a lawful basis to use;
Transmit your personal data you have provided to Santen to another controller where technically feasible (data portability);
Stop a particular processing when you withdraw your consent, at any time and free of charge;
Object to any processing based on the legitimate interests or public interest to process information, unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
Restrict certain aspects of the processing of your information.

You can withdraw any consent you have given (for example, for non-essential cookies or optional embedded services) at any time, including via the cookie preferences tool, without affecting the lawfulness of processing before withdrawal. We may ask you for information necessary to verify your identity before acting on your request, and we will respond within the timeframes required by applicable law.

All data protection related requests should be addressed to Santen EMEA Privacy Office at privacy-emea@santen.com.

If we do not handle your request in a timely manner, or if you are not satisfied with our response to any exercise of these rights, you are entitled to lodge a complaint with the competent supervisory authority of your place of residence or work. Further information and contact details of the competent European supervisory authorities can be found here.

If you are in the EEA, you may contact your national data protection authority; if you are in the UK, you may contact the Information Commissioner’s Office (ICO); if you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner (FDPIC).

Policy updating

Santen reserves the right to amend this Policy from time to time to reflect technological advancements, legal and regulatory changes, and Santen’s business practices, subject to applicable laws. If Santen changes its privacy practices, an updated version of this Policy will reflect those changes by posting any revisions on the Website and with the respective update of the effective date listed on the bottom of this Policy. We therefore encourage you to periodically visit this page to stay informed of how we are using your personal data.

Contact information

If you have any questions in relation to this Policy, or you want to obtain more information about Santen’s privacy practices, please contact our Santen EMEA Privacy Office by email at privacy-emea@santen.com.

Last updated: 22 August 2025