Effective date: November 25, 2020
1. How to contact us.
2. The information we collect about you.
3. How we may use your information.
4. Who we may share your information with.
5. How we safeguard your personal information.
6. How long we store your personal information.
7. Your rights and options regarding your personal information.
8. Special notice to non-U.S. users regarding data transfers.
9. Sensitive Information.
12. Governing law and jurisdiction.
1. HOW TO CONTACT US
You can update your preferences and information by updating your contact information through our Sites or contacting us at the e-mail address or phone number below. Additionally, if you have any questions or concerns about our use of your Personal Information (defined below) or wish to communicate with our privacy official, please do not hesitate to contact us through any of the methods below.
2. PERSONAL INFORMATION
While using our Sites, we may ask you to provide us with certain personally identifiable information (“Personal Information”). Personal Information is information that identifies, relates to, describes, can reasonably be associated with, or can reasonably be linked to a particular individual or household.
We collect information from you both when you provide it voluntarily and also automatically when you use our Sites. We may also collect Personal Information from other sources, as described below.
We collect Personal Information from you and any devices (including mobile devices) you use when you use our Sites, provide us information on a web form or survey, or when you otherwise correspond with us (including through Twitter).
INFORMATION WE COLLECT ABOUT YOU
We may collect the following categories of Personal Information from you, depending on your interactions with our Sites and the choices you make, as further described in the chart below:
- Identifiers: Your name, email address postal address, unique personal identifier, and Internet Protocol (IP) address.
- Internet or other electronic network activity information For example:
- Browse history: Data about the webpages you visit.
- Search history: Data about the search terms you enter.
- Device, connectivity, and configuration data: Data about your device and nearby networks, including regional and language settings.
- Geolocation data: Data about your device’s location, which is inferred from your IP address and your postal address.
- Demographic data: Data about you such as your age, country, preferred language and other data reflecting your consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Health information: Data about your health status and conditions.
Information collected through use of our Site
The Data is Not Available
3. HOW WE MAY USE YOUR INFORMATION
We will only use your information for the purposes identified below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose described here. If we need to use your Personal Information for an unrelated purpose or if we change the basis on which we are processing your data, we will notify you and we will explain the legal basis which allows us to do so.
You can browse through our Sites without telling us who you are. However, some of our other services, such as submitting your information in volunteering to participate in clinical trials, do require that you provide your personal details, as described above. This allows us to process and/or send you information that you request about specific clinical trials or potential trials which you may be suitable for. We may also use your email address to contact you and introduce new products or to otherwise share additional materials supporting our mission of connecting challenge trialists with eligible, well-informed volunteers.
Where we make available the option to provide Personal Information that relates to your health, we request your consent. In doing so, we also explain, for that program or service, how we plan to use your personal information. We also offer you the option of discontinuing your if you later decide that you no longer want to participate in that program or receive additional information from us.
We may also use your personal data in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest.
In addition, when you visit the Sites, we and third parties collect information about you if your computer is set to allow that type of collection. This includes cookies, IP address and device ID. You can turn off the ability to collect some of this information from your computer or device settings.
Where we rely on “legitimate business interests” as the reason for processing your information, we have determined, acting reasonably and considering the circumstances, that we are able to process your Personal Information in accordance with data protection laws on the basis that we have a legitimate business interest.
We have a legitimate business interest in processing your Personal Information as:
- We need the information to respond to your inquiries
- We need the information to send you information, and
- We would be unable to administer our Sites without processing your information.
We consider that it is reasonable for us to process your Personal Information for the purposes of our legitimate interests outlined above as (a) we process your Personal Information only so far as is necessary for such purpose and (b) it can be reasonably expected for us to process your Personal Information in this way. In most cases, the information is being processed for your benefit as well as ours.
If we wish to process your existing information for a new purpose other than as stated above, and you are located in the European Union, California or any other jurisdiction that has passed a similar data privacy law, we must inform you of that further processing and provide information surrounding your information’s use.
4. SHARING YOUR INFORMATION
We share non-Personal Information with third parties at our discretion. We do not sell your Personal Information or share your Personal Information for our commercial benefit.
If you submit our volunteer form, we will contact you with opportunities to participate in human challenge trials or related advocacy activities as they become available. If you have consented to have your contact information shared with organizations to participate in related research opportunities, we may share your email address with researchers conducting studies relating to COVID-19 human challenge studies or related endeavors.
In connection with our Site, we may share your Personal Information with certain third parties who we engage to help us run our business and perform the services, including under the following circumstances:
- Software and service providers we use to manage and process your information.
- Affiliates and subsidiaries.
- Google Analytics, a service provided by Google, Inc., to gather information about how you and other users engage with our Site. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners.
- Other third parties that you expressly request us to share your Personal Information with.
Additionally, we will share your Personal Information with third parties where required by law, where it is necessary in connection with our Site, or where we have another legitimate interest in doing so.
Most of the third parties with whom we share your Personal Information are located and store your information in the United States, although some may be located or store your information outside of the United States.
If we are subject to a merger or acquisition with/by another company, we may share information with them in connection with the transaction.
5. HOW WE SAFEGUARD YOUR INFORMATION
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of Personal Information is at your own risk.
6. HOW LONG WE STORE YOUR INFORMATION
We also will retain Usage Information for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when Usage Information is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain Usage Information for longer periods.
7. YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION
Marketing Preferences. You can opt out from receiving future communications from us at any time by using the unsubscribe function in the email you receive from us, or contacting us as set forth under “How to contact us” above. Please allow sufficient time for your preferences to be processed. Even if you opt out of receiving marketing messages, we may still contact you for transactional purposes like confirming or following up on a service request, or asking you to review a service you have used. If you later opt back into getting communications from us, we will remove your information from our opt-out databases.
Cookies. Cookies are small data files that are downloaded onto your computer or mobile device when you use our Site, which are unique to your device or account. You can choose whether to accept cookies by changing the settings on your browser or device. However, if you choose to disable cookies, your experience with our Sites may be impaired and some features may not work as they were intended.
If you are located in the European Union, you have the following rights with respect to your data under certain circumstances:
- The right to request access to your Personal Information and the following information regarding our use of your Personal Information:
- The purpose of such use
- The categories of your Personal Information that we have used
- Who we have disclosed your Personal Information to
- The right to request us to correct any inaccurate Personal Information concerning you.
- The right to request us to erase your Personal Information when we no longer need such data in connection with our services or, with respect to “special categories” of Personal Information, if you withdraw consent to our use of such information.
- The right to withdraw consent to our use of Personal Information, if we are relying on consent to use your Personal Information.
- The right to request us to restrict our use of your Personal Information (e.g., suspend our use of your Personal Information).
- The right to object to our use of your Personal Information where we are not using it to perform services you have requested from us.
- The right to receive a copy of your Personal Information.
- The right to lodge a complaint with the supervising authority of your country.
- A list of National Data Protection Authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you want to exercise any of the rights listed above, please contact us through one of the methods listed in Section 1 above.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. Please understand that we are required to verify your request and may require you to provide some information to enable us to carry out such verification. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
8. TRANSFER OF DATA, SPECIAL NOTICE TO NON-U.S. USERS
9. SENSITIVE PERSONAL INFORMATION
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal information as this term is defined under applicable data protection and privacy laws (for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Sites or otherwise to us (excluding any health information which you may voluntarily choose to submit to us when specifically asked to provide health information through a survey presented in connection with the Sites).
10. POLICY ON CHILDREN’S INFORMATION
Our Sites is not created for anyone under the age of 13 (“Children” or “Child”). By using the Site, you represent that you are at least 13 years old. If you do not meet this age requirement, then you must not access or use our Site.
We do not knowingly collect personally identifiable information from anyone under the age of 14, and we do not target the Sites to children under the age of 13. If you are a parent or guardian and you are aware that your Child has provided us with Personal Information, please contact us though one of the methods listed under “How to Contact Us”, above. If we become aware that we have collected Personal Information from Children without verification of parental consent, we take reasonable steps to remove that information from our servers.
For more information about the Children’s Online Privacy Protection Act (“COPPA”), which applies to websites that direct their services to children under the age of thirteen (13), please visit the Federal Trade Commission’s website https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions.
11. LINKS TO OTHER SITES
12. GOVERNING LAW AND JURISDICTION