Effective as of March 9, 2023

This Privacy Policy describes the privacy practices of Function Oncology, Inc. and affiliates, (collectively, “Function Oncology”). This Privacy Policy describes how we collect, use, and store (together “process”) an individual’s personal data and explains the rights and choices available to individuals. This Privacy Policy applies where we are acting as a data controller with respect to the personal data of our website visitors and any other individuals who interact directly with Function Oncology; in other words, where we determine the purposes and means of processing the personal data.

Function Oncology may provide additional privacy notices to individuals at the time we collect their data that describe our privacy practices in connection with specific activities and will apply to the information you provide at that time, in addition to this Privacy Policy.

Please note this Privacy Policy does not apply to Function Oncology’s processing of employee or contractor data.


How We Collect Your Personal Data

You directly provide Function Oncology with most of the data we collect. We collect and process your personal data when you:

  • Provide the information to us via email
  • Enter your personal data via our websites
  • Use or view our websites via your browser’s cookies

Types of Personal Data We Collect

The types of personal data we collect include:

  • Personal and business contact information and preferences (such as name, job title and employer name, email address, mailing address, phone number, and emergency contact information)
  • Other information you provide to us (such as in emails, through our websites, or in other correspondence)

How We Use Your Personal Data

To the extent permitted by applicable local law, we collect your personal data for the following purposes:

  • Communicating with you about the products and services we offer, and responding to requests, inquiries, comments, and suggestions;
  • Analyzing and enhancing our communications and strategies (e.g. effectiveness of emails or our websites);
  • Operating, securing, and improving our business (including both physical premises and digital environments);
  • Developing and personalizing customer relationship management activities, including the delivery of programs and materials, as well as surveys and market research;
  • Complying with regulatory monitoring and reporting obligations (including those related to adverse events, product complaints, spend transparency, and patient safety); and
  • For other purposes for which we provide specific notice at the time the information is collected.

In some situations, we may have a separate agreement or relationship with you with respect to a specific type of processing of your data. These situations will be governed by specific terms, privacy notices, or consent forms that provide additional information about how we will use your personal data that we collect at that time.

Personal Data We Share

Function Oncology may share your personal data with our service providers and third parties with which we contract for the purposes described in either this Privacy Policy or through a specific “in-time” privacy notice provided at the time we collect the information.

Affiliates. We may share any information we receive with our current or future affiliates for any of the purposes described in this Privacy Policy.

Merger, Sale, or Other Asset Transfers. Unless prohibited by applicable law, we may transfer your personal data as part of a corporate business transaction, such as a merger, acquisition, reorganization, joint venture or the sale of our assets. We may also transfer your personal data to a successor entity in the event of insolvency, bankruptcy or receivership.

As Required by Law and Similar Disclosures. We may share your personal data to comply with legal and regulatory requirements, comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by a federal, state, or local authorities, and protect against fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and exercise or defend legal claims.

Consent. We may also disclose your information with your permission.

Function Oncology does not sell your personal data or make your personal data available to any other party for their own proprietary purposes, except as required by applicable law.

Cookies and Other Automated Information Collection

Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For additional information about cookies, visit

Function Oncology may also collect certain information about the use of our websites by automated means, such as cookies, web beacons and other technologies (“Automated Information”). We may collect Automated Information about your online activities over time and across our own and third-party websites when you use our websites, including to deliver commercial content on our behalf. In jurisdictions where Automated Information is considered personal data, or if we associate Automated Information with personal data, we will treat Automated Information as personal data and process such information in accordance with this Privacy Policy.

The Automated Information that we collect from time to time includes:

  • Details about the devices that are used to access our websites (e.g. IP address, and type of operating system and web browser);
  • Dates and times of visits to, and use of, our websites;
  • Details about your interactions with emails that we may send you, including the links on which you click and your interactions with our linked sites;
  • Information about how our websites are used (such as the content that is viewed on our websites and how users navigate our pages); and
  • URLs that refer visitors to our websites

Web browsers may offer users of our websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. You can visit for information about cookies and how to disable them.

Legal Basis for Processing Data

In some cases, Function Oncology has a legitimate interest to process your personal data that we collect, such as to operate, evaluate and improve our business; to facilitate and manage clinical trials; to promote scholarly research; to support our clinical trial recruitment activities; to facilitate a sale of our assets, merger or acquisition; and fraud prevention. We may also process your personal data as necessary for the protection against criminal offenses, safeguarding of domestic law, and the maintenance of a safe workplace for staff.

It may be also necessary for Function Oncology to process your personal data to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including enforcing the terms and conditions that govern the services we provide.

Function Oncology’s processing of your information may be necessary to comply with our legal obligations, and for reasons of public interest in the area of health or for scientific or historical research purposes, such as with respect to adverse event and product safety reporting.

Function Oncology may also process your personal data as specifically permitted by applicable legal requirements, such as laws and regulations that authorize Function Oncology to process your personal data for purposes of conducting clinical trials.

When Function Oncology relies on consent for the processing of your personal data, we will seek your consent at the time we collect your personal data. For information on how to withdraw consent, please see the “Personal Data Access Rights” section of this Privacy Policy.

Personal Data Access Rights

You have the right to exercise the following rights in relation to the personal data that we collected about you. Please note that if your exercise of these rights limits our ability to process your personal data, we may not be able to provide our products or services to you, or to otherwise engage with you going forward.

We will verify the identity of each individual making any request regarding personal data, to help ensure that we provide the information only to individuals to whom the personal data pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that personal data. In the event we cannot comply fully or at all, with your request, we will notify you of the reasons.

Right to Withdraw Your Consent

Where you provided consent to Function Oncology to process your personal data, you may withdraw such consent by following the instructions provided at the time of collection or by contacting us using details in the Contact Us section below. In some instances, withdrawing your consent may mean we can no longer provide products or services to you or otherwise engage with you.

Right to Access Your Personal Data

You have the right to request from Function Oncology copies of the personal data that we maintain about you. This includes the right to request us to disclose to you the: categories of personal data we collected about you; categories of sources from which the personal data is collected; business or commercial purpose for collecting your personal information; categories of third parties with whom we share your personal information; and specific pieces of personal information we collected about you.

Right to Rectification

You have the right to request Function Oncology to correct any errors in your personal data. You also have the right to request us to complete personal data you believe is incomplete.

Right to Object to Processing of Your Personal Data

You have the right to object to or “opt-out” of our processing of your personal data.

Right to Erasure

You have the right to request that we delete your personal data from our records, under certain conditions.

Right to Data Portability

You have the right to request that Function Oncology transfer personal data that you provided to us to another organization, or directly to you, under certain conditions.

No Discrimination

You have the right to not be discriminated against by Function Oncology because you exercise any of the above rights.

You have the right to file a complaint with a regulator or data protection supervisory authority in your jurisdiction.

As stated above Function Oncology does not “sell” personal data as that term is defined under privacy applicable laws. To request further information about this, you can do so by emailing When submitting a request to exercise any of these rights, please describe your relationship with us and your request, with sufficient detail to allow us to properly understand, evaluate, and respond to it. We will need to verify your identity before processing your request, which may require us to request additional personal data from you.


We do not knowingly collect personal data from children under age 13 through our websites. If we learn that we have collected personal data directly from a child under the age of 13 through our websites, we will delete that information.

How We Protect Personal Data

Function Oncology securely stores your data and maintains reasonable and appropriate administrative, technical and physical security procedures and practices designed to protect the personal data we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot guarantee that the measures we maintain will ensure the security of your personal data. We will keep your personal data in a form that permits identification of you only for as long as necessary for the purposes for which it was processed.

Links to Third-Party Websites and Content

For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by Function Oncology. The websites and third-party content to which we link may have separate privacy notices or policies. Our privacy policy applies only to our websites and applications, and Function Oncology is not responsible for the privacy practices of any entity that we do not own or control, or for the legality of any third party content. If you click on a link to another website, you should read the privacy policy associated with that website.

Information for California Consumers

This section describe how we collect, use, process, and disclose personal data of California consumers and the rights you may have under California law. These disclosures are intended to supplement this Privacy Policy with information required by California law.

To understand what personal data we may have collected about you, and from where we collected it, please see the “Types of Personal Data We Collect” section.

We collect personal data to operate, manage and maintain our business and to accomplish our business purposes and objectives, as further described in the “How We Use Your Personal Data” section.

Function Oncology may share your personal data with our service providers and third parties with which we contract for the purposes described in this Privacy Policy. For more information on how your information is shared, please see the “Personal Data We Share” section.

Sale of Personal Data

We do not “sell” personal data. However, our use of some cookies and similar technologies may be considered a “sale” under California law. California law defines “sale” broadly to include any disclosure of information in return for any value. The value does not need to be monetary like in a traditional sale. The disclosure of personal data through cookies and similar technologies ay qualify as a sale under California law. You can opt out of these cookies and similar technologies.

Your Rights

Under California law, you have a right to notice, upon collection, of the categories of personal data collected and the purposes for which the information will be used. In addition, California residents may have additional rights, subject to certain limitations, including:

  • Access: You may have the right to access a copy of the categories and specific pieces of personal data that we have collected, used, and/or disclosed.
  • Correction: You may have the right to request that we correct inaccurate personal data that we hold about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
  • Deletion: You may have the right to request that we delete or anonymize your personal data, with certain exceptions.
  • Sale/Sharing Opt-Out: You may also have the right to opt-out of the sale of your personal data.
  • No Retaliation: You have the right to be free from discrimination for exercising your rights.

If you wish to exercise any of these other rights or have any questions regarding the processing of your personal data, contact us as provided in the “Contact Us” section below.

International Visitors

We operate in the United States and our servers and offices are located in the United States and intended for visitors located within the United States. If you choose to use our websites from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our websites. By providing any information, including personal information, on or to our websites, you consent to such transfer, storage, and processing.

Updates to Our Privacy Policy

Function Oncology keeps its privacy policy under regular review and places any updates on this web page. When we update this Privacy Policy, we will notify you of changes that are deemed material under applicable legal requirements by providing notification as required under applicable law. We may also notify you of changes to the Privacy Policy in other ways, such as via email or other contact information you have provided.

Contact Us

You may contact us with questions, comments, or complaints about this Privacy Policy or our privacy practices, or to exercise your rights regarding your personal data processed by us. When raising a request or complaint, please provide sufficient details (including your relationship with us) and any relevant documentation. Our contact information is:


Function Oncology, Inc.
9880 Campus Point Drive, Ste 410
San Diego, CA 92121