Privacy Policy

Introduction

ClinCloud, together with our affiliates and subsidiaries (collectively, “ClinCloud”, “we”, us” or “our”) is committed to protecting the privacy and security of your personal information. This Privacy Policy (“Privacy Policy” or “Policy”) describes the types of personal information and other information we collect from and about you when you interact with us or use our websites, web portals, mobile applications, social media pages, electronic communications, and other offline interactions you have with us and/or other services (collectively, the “Services”) and how we use, disclose, share and protect your information.  We respect your security concerns and are committed to protecting your privacy and personal data (“Personal Data”).

It is important to note that this Privacy Policy may contain information not applicable to you because of where you are located or the type(s) of personal information we collect about you.

Certain types of information we collect may be covered under another policy, such as our privacy policy for employees, or our privacy policy for healthcare providers who participate in our clinical trials. If your information falls under one of these other privacy policies, then the terms of the other privacy policies will apply.

Our Services may contain links to third-party websites. This Privacy Policy does not apply to third-party and/or sponsor-specific websites that we may operate or provide links to on their behalf.  Once you leave our Services, we are no longer responsible for the protection and privacy of any information you provide.

Adherence to this Privacy Policy may be limited to the extent required by law, regulations or other governmental obligations, and we reserve the right to share Personal Data as required or authorized by law or regulation or requested by governmental authorities. In accordance with applicable privacy laws, this Privacy Policy may not apply or may be limited with respect to data processing activities necessary for the performance of a contract between you and us.

 

This Policy tells you, among other things:

What is Personal Data?

Personal Data is information from which an individual may be identified directly or indirectly. Personal Data may include one or more factors specific to an individual such as your first and last name, postal address, zip or postal code, phone number, email address, date of birth, online identifiers such as your IP address, or other device, network and browsing information, and health, financial, employment-related and professional information, or inferences which may be drawn from other Personal Data. Personal Data may also include certain other identifiers.

What Personal Data we collect about you and the Sources from which we collect it;

• Data you provide directly to us.
• Data we collect automatically.
• Information and Data obtained from other sources.

The legal bases for processing your Personal Data;

To process your Personal Data, we must have a valid reason to do so. Some of these lawful bases for processing include, without limitation, your consent; legitimate interests, such as business interests in marketing our Services; compliance with legal obligation and protection of individuals, and/or any other ground permitted or required by applicable law. If your Personal Data is processed on the basis of legitimate interests, you have a right to ask us more about the choice of that legitimate basis. We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you

For what purposes we use Personal Data;

Personal Data may be used in providing the Services to you, including contacting you regarding current or future opportunities to participate in clinical research related activities, responding to your requests, contacting you with confirmations, account information, notification and other operational communications, and for other reasonable purposes. Personal Data may also be used for marketing purposes, including email communications, text messages, and/or other means of communication for the purposes of informing you regarding our Services and/or other topics that may be of interest to you.  We may also use your Personal Data in connection with analyzing Personal Data for business reporting and providing personalized services to you and others.

We may aggregate and/or anonymize Personal Data provided by multiple persons such that it no longer specifically identifies you or any other individual, and therefore is no longer deemed Personal Data.  We may also use your Personal Data in connection with our efforts to accomplish our business purposes, including without limitation, to comply with all applicable legal and/or regulatory requests or requirements, or to enhance our existing Services and/or develop new products or Services.

Our policies with respect to retention of Personal Data;

We retain your information for as long as it is necessary for the purposes set out in this Privacy Policy, including the purposes for which we collected your Personal Data or any other permitted purposes, unless required by law to retain it for a longer period of time.

How we protect your Personal Data;

We deploy and make use of a combination of security measures, technologies, processes, procedures and safeguards which are reasonable in our efforts to protect your Personal Data from unauthorized use, access or disclosure.

However, no method of safeguarding information is completely 100% secure. While we use measures designed to protect Personal Data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Sites is or will be secure.

How do we share your Personal Data;

We may share information about you including individual identifiers, Internet or similar network activity, professional or employment-related information, or other inferences drawn from other Personal Data. By your use of our website(s) and Services, you acknowledge that we will transfer your Personal Data to, and store your Personal Data in, jurisdictions which may have different data protection rules than in your country. Further, by your use of our website(s) and Services, you expressly acknowledge and agree that Personal Data will be stored and processed in your region, in the United States, and in any other country where we or our affiliates, subsidiaries, or service providers operate. Accordingly, your Personal Data may become accessible as permitted by law in those territories, including to law enforcement and/or national security authorities in those territories.

We may share this information with our affiliates and business partners, as well as third-party providers and social media platforms. We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business. Such third-party recipients may include third parties we utilize or for whom we provide services related to clinical trials.  These recipients will be required to use your Personal Data only for appropriate purposes, and will be required to take appropriate measures to protect your Personal Data.

How do we share Other Data;

Other Data does not include Personal Data, but may include any information that does not reveal your specific identify or does not directly relate to an identifiable individual.  We reserve the right to transfer, use, sell or share aggregated, anonymous data for any legal purpose. Such purposes may include, without limitation, analysis or usage trends, or in an effort to identify or collaborate with advertisers, sponsors and/or customers

Your choices and your rights about the Personal Data we collect about you;

Your Choices.    We respect your choices regarding your Personal Data, and the collection and processing of that Personal Data.  Certain Personal Data is required for us to provide certain Services.  It is important that you know you are under no obligation to provide us with any of your Personal Data; however, if you choose not to do so, you may not be able to utilize certain features or functionalities we offer, or to become aware of certain opportunities we may provide now or in the future. This is your choice, and we respect your decision to share or not share your Personal Data.

Your Rights.    You have the right to request access to your Personal Data, and/or to correct, revise, update, restrict, curtail or delete your Personal Data.  You also have the right to opt out of the processing of your Personal Data, or to object to the processing of your Personal Data. Where provided by applicable law, you may also have the right to request a copy of your Personal Data. If you would like to exercise any of these rights which may be available to you under applicable laws, please contact us using the contact information provided within this Privacy Policy.  Any requests should explicitly and clearly articulate the nature of the request, and if applicable, the specific information that is the subject of such request.  We may choose not to respond or effectuate any such request if the same is unclear, or we are not able to verify the identity of the person(s) originating such request. Any response to such requests shall be provided in a manner consistent with applicable laws.

Notwithstanding anything to the contrary in this Privacy Policy, or any request you may make with respect to your Personal Data, we may have a legitimate need to retain certain data and/or information, including but not limited to for our recordkeeping purposes.

Cookies, Advertising, Location Information and Communications Opt-Out;

Your web browser controls may be adjusted to help you manage your cookie settings.  If you would like to accept or reject certain cookies for our website(s), you can refer to those browser controls to adjust your personal settings.  Certain third-party service providers that deliver display and banner ads on the internet may be employed by us for those services, and may use cookie and/or pixel technologies in connection with those tailored advertisements. In addition to managing your preferences through an icon that may appear on some of such display or banner ads, you may also be able to manage your third-party advertising preferences through the Network Advertising Initiative. Certain settings on your mobile device and/or web browsers may allow you to manage your permissions and limit or prevent our ability to receive location information.  Please refer to your device manufacturer or operating system instructions for instructions on how to do this.  You may opt out of receiving marketing or other communications from us at any time through a given communications channel (such as text, email or telephone) by following the opt-out link or other unsubscribe instructions provided in the communication received, or by contacting us as provided below.

Children’s Privacy Protections;

Our Services are not targeted towards, nor intended for individuals under the age of eighteen (18) years of age.  We do not knowingly collect any Personal Data from individuals under the age of eighteen (18) years old.  Further, we take the rights and protections of children very seriously, and accordingly we request that individuals under the age of eighteen (18) do not provide us with any Personal Data without first receiving knowing and voluntary consent from their parent (or legal guardian) to provide us with such Personal Data, particularly where such consent is required by applicable law.

Third-Party Websites and Services;

In the course of providing our Services, we may make reference to or provide links to third-party websites and services as a convenience to you.  This may include links to unaffiliated third parties, including service providers and other third parties with whom we may do business.  It is your choice to access these third-party websites and/or utilize third-party services; however, when you choose to access any third-party site or service, you do so at your own risk.  We are not, and shall not be, in control of or responsible for any third-party website and services, or the content, security or personnel acting on behalf of any such third party. This Privacy Policy does not apply to any such third-party websites and/or services.  For the policies applicable to any such third-party website and/or services, please refer to the respective third party’s policy regarding privacy and collection of your Personal Data.

How to contact us;

If you have any questions or concerns about this Privacy Policy and/or how we process Personal Data, or would like to exercise any applicable legal rights set forth above, please contact via the methods provided below:

ClinCloud

1551 Sandspur Road

Maitland, FL 32751

Phone: (407) 636-4031

Modifications and Updates to this Privacy Policy;

We reserve the right, in our sole discretion, to make modifications, updates, or other changes to our Privacy Policy at any time, and without notification to you regarding any such revisions. In the event you need to make reference to our current Privacy Policy, please periodically check back to our website(s) as we will post all such changes on the website(s), and any such changes shall become effective immediately upon posting of such revised Privacy Policy.

Additional Information for Residents Located in the European Economic Area, Switzerland and/or the United Kingdom;

Those persons located in the European Economic Area, Switzerland and/or the United Kingdom may have certain rights with respect to their Personal Data as provided by applicable data protection laws and regulations.  Depending on the circumstances related to the processing of your Personal Data if you are located in those jurisdictions, your rights may include:

• To be Informed.              This Policy informs you of how we process your Personal Data.  In the event that any Personal Data is not collected directly from you, under GDPR and/or other applicable laws, there may be certain exemptions from our obligation to inform you.
• To Access. Subject to certain exemptions, you may have the right to access your Personal Data and other information about our processing of your Personal Data.
• To Object. In the event you have the right to object to processing, we will no longer process your Personal Data unless we can demonstrate compelling and legitimate grounds for such processing which override your interests, rights or freedoms; or where necessary to establish, exercise or defend a legal claim.
• To Rectify. You have the right to request correction of any inaccurate Personal Data about you that we process.
• To be Forgotten. Also known as the right to erasure, you may request the deletion of certain Personal Data we process about you.  If for some reason this request cannot be fulfilled, where practicable, we will consider limiting our use of your Personal Data.
• To Data Portability. You have the right to request that we provide you with a portable copy of your Personal Data. You may keep that copy for yourself, or move it elsewhere.
• To Withdraw Your Consent. At any time, where we rely on your consent as the legal bases for processing your Personal Data, you may withdraw that consent. However, any such withdrawal will not impact or negate the lawfulness of our processing prior to such withdrawal, nor will it affect the validity of Personal Data that is processed on other legal grounds.
• Of Non-Discrimination. We will not discriminate against you for exercising any data subject right you have under applicable law.

Please note that we currently do not have offices, facilities or personnel located in the European Economic Area, Switzerland, and/or the United Kingdom, and are not currently providing services for clinical trials being conducted in any of those locations.  Accordingly, if you are a resident of any of those locations, any Personal Data you submit is submitted pursuant to your informed consent and voluntarily submitted to us with the knowledge and understanding that we have not requested you provide any Personal Data for any reason, and further that you may not be able to receive the benefit of any Services we may provide.

Additional Information regarding California; and

The following provisions of this Privacy Policy apply solely to those consumer(s) and/or household(s) residing in the State of California.  However, please be advised that the provisions within this section of the Privacy Policy do not apply to, and Personal Data for such California residents does not include any information excluded from or otherwise not regulated by the California Consumer Privacy Act, as amended, (“CCPA”).  In accordance with the CCPA, we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents:

We have collected or plan to collect the following categories of Personal Data from California residents within the last 12 months:

We may receive this Personal Data directly from you, the California resident, or from the other Sources set forth above in this Privacy Policy.

Our policies regarding retention, use and disclosure of Personal Data, including but not limited to Personal Data collected from California residents, is also set forth above in this Privacy Policy.

California residents from whom we collect Personal Data may, upon our confirmation of a verifiable consumer request from such person, may request to receive information from the past 12 months regarding: the categories of Personal Data, categories of sources of Personal Data, the business or commercial purpose for collection of such Personal Data, categories of third-parties with whom we shared such Personal Data; specific pieces of Personal Data we collected, and/or if we sold or disclosed your Personal Data for a business purpose, and the categories of third parties who purchased such Personal Data.

Upon our receipt and confirmation of a verified request from such person, California residents may have the right to request:  deletion of the Personal Data we collect about you, correction of inaccurate Personal Data, limitation of our use and disclosure of certain sensitive Personal Data, subject to certain exceptions.

To exercise any of the rights outlined herein, and/or otherwise available to California residents under the CCPA, California residents should submit a verifiable request to the contact information provided within this Privacy Policy, and in connection with any such request be prepared to provide reasonably requested information we may require in order to verify the identity of the person making such request and any other reasonably related information regarding such request. In the event we cannot fulfil any such request, or are permitted to decline such request, we will inform you accordingly. We will select the format in which any information is provided in response to any data portability requests.

In the event any request is made by an individual who is not authorized to make such request, is unfounded, excessive, repetitive or otherwise unreasonable, we reserve the right in our sole discretion to decline to respond to any such request, or to charge you a fee in order to provide a response.

Any other additional information related to any state or country-specific laws and regulations.

States within the United States and countries around the world continue implementing additional laws that pertain to the protection of Personal Data, and the rights of the individuals to whom such data belongs or relates.  While the defined terms used to describe Personal Data under those policies may not be the same across each of these policies and regulations, our commitment to protecting your Personal Data and complying with applicable laws and regulations with respect to the Personal Data we collect does not waiver.

If you have a question regarding our collection, use, processing, sharing, transferring, or other treatment with respect to your Personal Data, please send a verifiable, written request to our contact information provided in this Privacy Policy, detailing, specifically, the nature of your inquiry, and setting forth the Personal Data to which your question relates, and the means by which it was collected by us.