Effective on March 15, 2023
Personal Information You Provide
We may collect the following personal information that you provide through our Platform or otherwise::
Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., 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 Platform, or otherwise to us.
In addition, Client Users may be able to use the App to provide our customers with additional types of personal information, including health information, which we will collect in accordance with their instructions.
Information about you, your computer, or your mobile device may automatically be collected on the Platform, such as:
The automatic data collection on the Platform may be facilitated by the following technologies:
We may also receive personal information about you from third parties, such as our business partners, the organization you work for, clinical trial sponsors and sites, ClinOne customers, our subsidiaries and affiliates, data licensors, marketing partners, and publicly-available sources, such as social media platforms.
Users of the Platform may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so
We may use your personal information to:
In addition, we use personal information about Client Users at the direction of our clients to provide them with our products and services, such as managing clinical trials, storing clinical and patient engagement data, and generating applicable modules and reports.
We may use your information for research and development purposes, including to improve the Platform, understand and analyze the usage trends and preferences of our users, and develop new features, functionality, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We reserve the right to use, transfer, sell, and share aggregated, anonymous data for any legal business purpose. The purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.
We may send you ClinOne-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the “Your Choices” section below.
We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
We may use your personal data and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of our Platform, products and services, business, databases and other technology assets; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Platform; and (e) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
In some cases we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
We may share information collected about you with any member of our group of companies, including subsidiaries, our ultimate holding company, and its subsidiaries. For example, we will share your personal information with our related companies to provide our products and services to you, where other companies within our group perform components of the full service offering.
We share personal information with third parties and individuals who perform functions on our behalf and help us run the Platform and our business. For example, service providers help us perform website and application hosting, maintenance, database management, cloud storage, document signature and management, web analytics, billing, email software, SMS/text messaging software, CRM software, payment processing, marketing, and other purposes.
We may disclose personal information collected about you with third parties in connection with any business transaction (or potential transaction) involving a merger, sale of company shares or assets, financing, acquisition, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).
We may also disclose information collected about you to law enforcement, government authorities, and private parties, if disclosure is necessary to comply with any applicable law or regulation, in response to a subpoena, court order, governmental inquiry, or other legal process, or as we believe necessary for the compliance and protection purposes described in section titled “Use of Personal Information” above.
We may share your personal information with persons, companies, or professional firms providing ClinOne with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.
This section provides additional disclosures applicable only to the ClinOne Trial Awareness program services.
You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), the European Interactive Digital Advertising Alliance (for European users – http://www.youronlinechoices.eu/), and the Digital Advertising Alliance (optout.aboutads.info). The opt-out preferences described here must be set on each device and/or browser for which you want them to apply. Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Sharing of Personal Information with the Trial Awareness Network. If you are a provider, ClinOne may share contact information about you, provided to us by our customers, with members of our Trial Awareness network, regarding the clinical trial you may be supporting for one of our customers. If you are a member of ClinOne’s Trial Awareness network, we will share your contact information with the local providers who are overseeing a clinical trial that may interest you based on the information you enter as a part of responding to our email campaign. As part of these services, we may also share contact information about you with the sponsors regarding the clinical trial you may be interested in.
Some ClinOne companies are headquartered in the United States, and we have service providers in the United States and other countries. Your personal information may be collected, used, and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.
European users may view the section below titled “Notice to European Users” for additional information regarding any transfers of your personal information.
We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect personal information from unauthorized processing. This includes unauthorized access, disclosure, alteration, or destruction. However, no security system is impenetrable, and ClinOne cannot guarantee the security of the Platform, nor that the information you supply will not be intercepted while being transmitted over the Internet; therefore, we are not liable for the illegal acts of third parties.
The Platform may contain links to other platforms and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.
In this section, we describe the rights and choices available to our direct users. If you are a patient or other individual using the App as part of the services we provide to our customers, please contact the relevant customer directly to submit any privacy requests relating to your personal information.
If you need to make changes, corrections, or request that we remove your information from our systems, you may email ClinOne at email@example.com. We may not accommodate a request if we believe the change would violate any law or legal requirement or cause the information to be incorrect. ClinOne will use reasonable efforts to honor the request, however, you understand that in may not be technologically possible to remove from our systems every record of your personal information. The need for us to backup and protect information from inadvertent loss may mean that a copy of your data exists in a form that is non-erasable or impossible for us to locate or remove.
You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us as described below. You may continue to receive service-related and other non-marketing emails.
Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.
Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with ClinOne are entitled to ask us once a year for information regarding the personal information we have shared, if any, with third parties for their direct marketing purposes. If you are a California resident and would like to submit such a request, please submit your request in writing to the email address listed in the section titled “CONTACTING US” below with “Shine the Light” in the subject line. The request must include your name, street address, city, state, and ZIP code and an attestation that you are a California resident. We are not responsible for requests that are not labeled or sent properly, or that do not have complete information.
The information provided in this section applies only to individuals in the European Union, the European Economic Area, and the United Kingdom (collectively, “Europe”).
If you are a Client User providing personal information in connection with the services provided by ClinOne to one of our clients, please contact the relevant client for information about the controller of your personal information for purposes of European data protection legislation.
Processing Purpose (as described above in the “Use of Personal Information” section)
To Provide the Platform
Processing is necessary to perform the contract governing our operation of the Platform, or to take steps that you request prior to engaging our services. Where we cannot process your personal data as required to operate the Platform on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request.
Research and Development
Processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business and delivering information of interest to you.
To Comply with Laws and Regulations
Processing is necessary to comply with our legal obligations.
For Compliance, Fraud Prevention, and Safety
Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety, or property.
With Your Consent
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Platform.
With respect to advertising that may be carried out in connection with ClinOne’s Trial Awareness program services, such processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our Trial Awareness program network and showing you relevant content.
Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Platform.
For questions about the legal bases our clients rely upon to process personal information we collect on their behalf, please contact the relevant client.
We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements
For personal information collected about Client Users on behalf of a client, the data retention period will be determined by the applicable contract that we have with that client.
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
You may submit these requests by contacting us at firstname.lastname@example.org or at the mailing address listed below. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
ClinOne complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (the “Privacy Shield”), as adopted and set forth by the U.S. Department of Commerce. At this time, we are continuing adhere to the Privacy Shield Principles and have certified our adherence to the Department of Commerce.
To learn more about the Privacy Shield, and to view ClinOne, Inc.’s certification, please visit https://www.privacyshield.gov and https://www.privacyshield.gov/list, respectively
If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, such as the Standard Contractual Clauses approved by the European Commission, we will do so. Please contact us at email@example.com for further information about any such transfers or the specific safeguards applied.
Where a privacy complaint or dispute cannot be resolved through our internal processes, we have agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure . Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Privacy Shield Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/
If your dispute or complaint can’t be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you under the Privacy Shield’s “Recourse, Enforcement and Liability Principle” and Annex I of the Privacy Shield.
ClinOne is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
We have appointed VeraSafe as our representative in the EU for data protection matters. While you may also contact us, VeraSafe can be contacted on matters related to the processing of Personal Data. To contact VeraSafe, please use this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative/ or via telephone at: +420 228 881 031
Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd
Unit 3D North Point House
North Point Business Park
New Mallow Road
VeraSafe Netherlands BV
Keizersgracht 391 A
1016 EJ Amsterdam
VeraSafe Czech Republic s.r.o.
VeraSafe has been appointed as ClinOne’s representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. If you are located within the United Kingdom, VeraSafe can be contacted in addition to or instead of ClinOne’s Data Privacy Lead, only on matters related to the processing of personal data.
To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +44 (20) 4532 2003.
Alternatively, VeraSafe can be contacted at:
VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
If you have any questions about this Policy or our processing of your personal information, please write to our Privacy Lead by email at firstname.lastname@example.org or by postal mail at:
Attn: Privacy Lead
117 Kendrick Street
Needham, MA 02494, USA
The previous version of this policy will be available for review until DATE at URL.