Privacy Policy

ClinOne Privacy Policy

Effective on: August 20, 2019


Introduction and Scope

ClinOne, Inc. (“ClinOne”, “we”, “us”, “our”) takes the protection of personally identifiable information (“Personal Data”) very seriously. This Privacy Policy (the “Policy”) addresses data subjects whose Personal Data we may receive from our customers or business partners (“Clients”) in our ClinOne Web Application and ClinOne Mobile Application, and directly from patients through our ClinTrialConnect Web Application (collectively, the “Applications”). This Policy does not apply to Personal Data we collect by other means, such as Personal Data that we receive directly through ClinOne’s own publicly accessible websites.


Controllership

ClinOne acts as an agent, also known as a data processor, for the Personal Data we process for our Clients when providing our Applications. This means that our Clients determine the type of Personal Data they provide for us to process on their behalf. We typically have no direct relationship with the individuals whose Personal Data we receive from our Clients.


Basis of Processing

Within the scope of this Policy, we process Personal Data based on the instructions of our Clients.


How We Receive Personal Data

In the ClinOne mobile and web applications, we may receive your Personal Data when:

  • You provide it directly to us through the ClinOne Client’s account on the ClinOne Web or Mobile Application; or
  • Our Clients (including their employees, contractors, and other representatives of the company) provide it to us.

In the ClinTrialConnect application, we may receive your Personal Data when:

  • You provide it directly to us through the ClinTrialConnect Web Application;
  • A clinical trial sponsor or clinical trial site provides it to us; or
  • Our service providers provide it to us.

Categories of Personal Data

In the ClinOne Mobile and Web Applications, we may process the following types of Personal Data:

  • Biographical information, such as first and last name;
  • Contact information, such as phone number, email address and postal addresses;
  • Device information, such as IP address, and browser version; and
  • Any other information posted by users in community forums.

In the ClinTrialConnect Web Application, we may process the following types of Personal Data:

  • Biographical information, such as first and last name;
  • Contact information, such as phone number, email address, and postal addresses;
  • Device information, such as IP address, and browser version; and
  • Health information.

Purposes of Processing

In the ClinOne Mobile and Web applications, we may process your Personal Data for the purposes of:

  • enabling the use of the ClinOne Mobile and Web Applications;
  • responding to your requests or questions;
  • managing clinical trials;
  • storing clinical trial information, team information, and clinical site information;
  • communicating available clinical trials to you; and
  • generating applicable modules and reports.

In the ClinTrialConnect Web Application, we may process your Personal Data for the purposes of:

  • enabling the use of the ClinTrialConnect Web Application;
  • Responding to your requests or questions;
  • completing and maintaining the patient engagement database; and
  • generating applicable modules, such as Electronic Patient Report Outcome (“ePRO”).

Data Retention

We retain Personal Data for as long as instructed by the respective Client (who typically acts as a data controller). We delete the Personal Data submitted to us by our Clients or applicable patients within ten years of the end of our service agreement with the Client, unless applicable laws require otherwise.


Sharing Personal Data with Third Parties

We may share Personal Data with our service providers, who process Personal Data on our behalf, and who agree to use the Personal Data only to assist us in providing our Applications or as required by law. Our service providers may provide:

  • application hosting services;
  • cloud storage services;
  • analytics services;
  • document signature and management services;
  • email software; and
  • CRM software.

Some of these third parties may be located outside of the United States. However, before transferring your Personal Data to these third parties, we will either ask for your explicit consent or require the third party to maintain at least the same level of privacy and security for your Personal Data that we do. We remain liable for the protection of your Personal Data within the scope of our Privacy Shield certification that we transfer to third parties, except to the extent that we are not responsible for the event that leads to any unauthorized or improper processing.


Other Disclosure of Your Personal Data

We may disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our subsidiaries or affiliates, but only if necessary for business purposes, as described in the section above.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data for any legal business purpose. Such data does not include any Personal Data. The purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.

If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.


Cookies

A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to provide basic relevant ads, website functionality, authentication (session management), usage analytics (web analytics), and to remember your settings, and generally improve our Applications.

We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Most of the cookies placed on your device through our Applications are first-party cookies, since they are placed directly by us. Other parties, such as Google, may also set their own (third-party) cookies through our Applications. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.

If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all of our Applications’ features. For more information, please visit https://www.aboutcookies.org/.

You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visit https://allaboutdnt.com/. Please note that our Applications do not have the capability to respond to “Do Not Track” signals received from web browsers.


Data Integrity & Security

We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing. This includes unauthorized access, disclosure, alteration, or destruction.


Access & Review

If we process your or your child’s Personal Data, you may have the right to request access to (or to update, correct, or delete) such Personal Data.

If we have received your Personal Data in reliance on the Privacy Shield, you may also have the right to opt out of having your Personal Data shared with third parties and to revoke your consent to our sharing your Personal Data with third parties. You may also have the right to opt out if your Personal Data is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you originally authorized. Requests should be sent directly to the ClinOne Client who provided your Personal Data to us. ClinOne has limited rights to access Personal Data our Clients submit to us. Therefore, if you contact us with such a request, please provide the name of the ClinOne Client who submitted your Personal Data to us. We will forward your request to that Client, and provide any needed assistance as they respond to your request.


EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

For Personal Data processed in the scope of this Policy, 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 regarding the processing of Personal Data transferred from the European Union, the European Economic Area, the United Kingdom, or Switzerland to the United States, or otherwise received in reliance on the Privacy Shield. We commit to 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.


VeraSafe Privacy Program

ClinOne is a member of the VeraSafe Privacy Program. This means that VeraSafe has assessed our data governance and data security (regarding Personal Data processed within the scope of this Privacy Policy) for compliance with the VeraSafe Privacy Program Certification Criteria. The certification criteria require that participants maintain a high standard for data privacy. Participants must also implement specific best practices regarding notice, onward transfer, choice, access, data security, data quality, recourse, and enforcement.


Dispute Resolution

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/


Binding Arbitration

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.


U.S. Regulatory Oversight

ClinOne is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.


Changes to this Policy

If we make any material change to this Policy, we will post the revised Policy to this web page. We will also update the “Effective” date.


Contact Us

If you have any questions about this Policy or our processing of your Personal Data, please write to our Privacy Lead by email at privacy@clinone.com or by postal mail at:

ClinOne, Inc.
Attn: Privacy Lead
1515 Wynkoop Street, Suite 360
Denver, CO 80202
USA

Please allow up to four weeks for us to reply.


European Union Representative

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
Cork T23AT2P
Ireland

VeraSafe Netherlands BV
Keizersgracht 391 A
1016 EJ Amsterdam
The Netherlands

VeraSafe Czech Republic s.r.o.
Klimentská 46,
Prague 1,
11002,
Czech Republic

2019 © ClinOne, Inc.  •   Version 2.108.1.5  •   Privacy Policy