Privacy Policy & Terms of Use
Clinilabs Drug Development Corporation Privacy Policy
Last updated: 28 January 2022
Our Commitment To Privacy
At Clinilabs Drug Development Corporation (“Clinilabs”, “we”, or “us”), your privacy is important to us. This Privacy Policy is intended to describe how we collect, use, and share information that we collect or obtain through the Clinilabs website (clinilabs.com) and all subpages (the “Site” or “Website”) and the choices you can make about the way your information is processed. We safeguard your information consistent with industry standards.
Scope of this Policy
This Privacy Policy applies to information that you submit or that we collect or obtain through the Site. Without prejudice to your rights under applicable law, the Privacy Policy is not contractual and does not form part of any contract between you and us.
This Privacy Policy also applies to the collection and processing of information on behalf of our business partners and clients, including processing of any information in connection with research studies or clinical trials. Our use of information on behalf of our partners and clients is governed by our Privacy Policy, our contract with that entity, and the entity’s own privacy policies and disclosures, subject to our explanations elsewhere in this Privacy Policy, such as the section titled “Research Volunteer Information” and the following paragraph. Clinilabs utilizes standard contractual clauses and other appropriate data transfer mechanisms when transferring data from the European Economic Area (“EEA”).
Please note that you may be able to submit information or inquiries to us in connection with becoming a study volunteer or investigator, through the Site or otherwise. The information you submit in connection with becoming a study volunteer is subject to our Privacy Policy. If you ultimately become a volunteer in a research study we conduct on behalf of one of our business partners and clients, any personal information processed in connection with your role as a volunteer will be governed by our business partner’s privacy policy, which will be available to you upon request, and not our Privacy Policy. The section titled “Research Volunteer Information” provides more information about collection, use, and disclosure of your information in that context. If you ultimately become an investigator in a research study, use of your personal information will still be governed by our Privacy Policy.
This Privacy Policy does not apply to any information you submit or otherwise provide directly to any third parties, such as a research organization.
This Privacy Policy also does not apply to other companies’ or organizations’ websites to which we link. You should carefully review the privacy policies of those websites in order to determine how they treat your personal information.
Information We Collect
Clinilabs may collect certain personal information from or about you because of your use of the Site, your submissions to the Site, and/or our provision of the Site’s services. You are not required to provide all personal information identified in this Privacy Policy; however, please be advised that if you do not provide the personal information requested, we may be unable to provide some or all of the services.
We may collect the following categories of personal information from you or about you, including:
- Research Volunteer Contact and Demographic Information. We may collect information such as your name, address, email address, phone number, fax number, job title, organization or company name, and other information you choose to submit to us through the Site. If you express interest in becoming a study volunteer with us, we also collect your date of birth, the type of study you are interested in, and any additional comments you may choose to submit. We may share your contact information with our vendors as described in the sections titled “How We Collect and Use Information” and “How We May Disclose Information.” If you express interest in becoming a study volunteer, we may also collect the information described in the following paragraph, titled “Research Volunteer Health Information,” for the reasons described in that paragraph and subject to the limitations in it
- Research Volunteer Health Information. We may collect sensitive personal information about you, such as your height and weight, your ethnicity, data related to your health, physical samples including blood and tissues, and/or your genetic data. Clinilabs has increased protections and restrictions in place when collecting, processing, and disclosing this category of personal information. If you provide this information, we store this information in a recruitment database and will use it to determine if you may qualify for a research study that we conduct. We do not share this information with our business partners or clients without your informed consent. Please see the section titled “Research Volunteer Information” for more information.
- Investigator Research Experience and Areas of Interest. If you register to become a member of the Clinilabs investigator registry, we also collect information related to your institution as well as professional training and research experience, such as contact information for your research coordinator/director, facility type, institutional review board information, as well as therapeutic areas of interest.
- Employment Applicant Data. If you apply for a job with us, we will collect information in connection with your application, such as your resume, education, employment history, and any other materials you may submit in conjunction with your application.
- Cookies, Device Information, and Similar Technologies. We may collect certain information using cookies and other technologies, such as web beacons, device IDs, HTML5 local storage, and IP addresses. Our “Use of Cookies and Similar Technologies” section contains more information on the information we may collect through these technologies and options to control or opt-out of certain data collection or uses related to cookies and similar technologies.
Anonymous or De-identified Data
We may create de-identified or anonymous data from personal information by removing data components (such as your name or email address) that make the data personally identifiable to you or through obfuscation or other means. Our use of anonymized data is not subject to or restricted by this Privacy Policy.
How We Collect and Use Information
We may collect personal information from the following sources, including:
- Interactions with the Site and communications with us. We may collect personal information when you use or interact with the Site. We also collect personal information when you communicate with or submit information to us in writing, via email, or other means, including when you submit inquiries or request information; when you sign up to receive or access communications, webinars, materials, or other information from us; and when you report issues or bugs with the Site. See the “Use of Cookies and Similar Technologies” section below for more information.
- Online communities and forums. We may collect personal information when you engage with our online communities, blogs, and forums, including any information you may provide through your interaction with or participation in our social media pages and groups. Please note that online forums may be publicly accessible and other users may view information you post in the forums and may also be subject to different or multiple privacy statements. We encourage you to exercise care in deciding what information and content you wish to disclose on the areas of the Site that are accessible to the general public.
- Volunteer and Investigator Registration. We collect personal information when you express interest in being a volunteer or register to become a member of the Clinilabs investigator registry.
- Job Applications. If you choose to apply for employment with us, we will collect personal information in connection with your application.
- Cookies and Similar Technologies. We may collect certain information using cookies and other technologies, such as web beacons, device IDs, geolocation, HTML5 local storage, and IP addresses, as further described in this Privacy Policy. Our “Use of Cookies and Similar Technologies” section contains more information on the information we may collect through these technologies and options to control or opt-out of certain data collection or uses related to cookies and similar technologies.
We use the information we collect as described in this Privacy Policy, including for the following purposes:
- to maintain, administer, develop, and improve the Site and its content and services, including to better tailor the features, performance, and support of our Site; for statistical and analytics purposes; and for marketing and advertising purposes;
- to contact and communicate with you, including to address and respond to inquiries or requests;
- to coordinate and administer registrations for, and participation in, research studies and participation in our investigator registry, which may include communicating with individuals who have expressed interest in being a study volunteer to coordinate their participation in studies or to notify them of new study opportunities;
- to administer the recruitment process and assess applications for employment;
- for fraud, loss, and other crime prevention purposes, to assist in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights, interests, and property, or the rights or safety of third parties;
- to enforce or comply with agreements or to comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process.
In addition, if you are volunteering for a clinical trial or study, please see the section titled “Research Volunteer information” for more information on how your information may be used.
How We May Disclose Information
We may disclose personal information to the following categories of entities, including:
- To our subsidiaries, affiliates, and other companies under our common control or within our corporate family for the purposes described in this Privacy Policy.
- To contractors, service providers, vendors, and other third parties we use to support our business and provide the Services, including for technical and processing functions, technical support, and analytics, for coordinating participation in studies or communication with individuals who have expressed interest in being a study volunteer, and for our direct marketing and advertising purposes.
- Business Partners and Clients. We may share certain information with our business partners or clients in order to coordinate your participation in research studies or trials, and we will not do so without your consent. As noted above, if you become a volunteer on a research study we conduct on behalf of a business partner or client, any personal information processed in connection with your role as a volunteer will be governed by our business partner’s privacy policy.
We may also disclose personal information for the following reasons, including:
- Legal and Compliance. To comply with any court order, law, or legal process, including to respond to any government or regulatory request, and to enforce agreements and to assert and defend against legal claims.
- Protection of Rights and Interests. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company or other third parties, and to investigate, detect, or prevent against fraud or other illegal activity.
- Corporate Transactions. Subject to applicable law, to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets. If any such transaction occurs, the purchaser will be entitled to use and disclose the personal information collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding personal information as described in this Privacy Policy.
In addition, if you are volunteering for a clinical trial or study, please see the section titled “Research Volunteer information” for more information on how your information may be disclosed.
Research Volunteer Information
As described elsewhere in this Privacy Policy, if you express interest in becoming a research volunteer for our future clinical studies, we collect your contact and demographic information; sensitive personal information, such as your ethnicity and/or your genetic data; and other information you choose to submit to us.
We store information we collect from you in a recruitment database and may use it to determine if you might qualify for research studies that we may conduct. We also may use your information to contact you regarding participation in our studies and to send you study-related emails, text messages, mailings, and newsletters. Please see our Volunteer Info FAQ and online volunteer sign-up page for more information about how we may use your information as a volunteer.
If you participate in a study or trial conducted by Clinilabs on behalf of one of our business partners and clients, we may share your information with our business partner to facilitate your participation. The information we share with our business partner or process in the course of a study or trial is subject to our business partner’s privacy policy, which will be available to you upon request. It is not subject to our Privacy Policy.
We will not share your information submitted in connection with being a research volunteer on a research study we conduct on behalf of a business partner or client without your consent.
Bases for Processing
We may use personal information for a variety of different purposes as set out in further detail in this Privacy Policy. Subject to applicable law, we process personal information pursuant to the following legal bases:
- To perform our contractual obligations to you, including to fulfil your request for services, or to take steps in response to information or inquiries you may submit prior to entering into a contract with us.
- To comply with laws, regulations, court orders, or other legal obligations, or pursuant to legal process. We will verify whether and to what extent we are legally obligated to share your personal information.
- For our legitimate interests, including to operate our organization and provide the Site and services. We will not process personal information pursuant to our legitimate interests where we believe such interests are overridden by the interests or fundamental rights and freedoms of the individual.
- To protect the vital interests of you or of another person.
- For the performance of tasks carried out in the public interest.
- With consent, where we are not already authorized to process the personal information under applicable law.
Use of Cookies and Similar Technologies
The Site may use cookies and similar technologies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization and performance/analytics and marketing and advertising. A “cookie” is a small text file that a web server stores in browser software. A browser sends cookies to a server when the browser makes a connection to the server (for example, when requesting a web page from the same domain that created the cookie). The purpose of cookies is to remember the browser over time and distinguish one browser instance (or user) from all others. Some cookies and other technologies may serve to track personal information previously entered by a web user on the site. Most browsers allow you to control cookies, including whether or not to accept them, and how to remove them. Cookies can remember login information, preferences, and similar information.
Cookies, as well as other tracking technologies, such as HTML5 local storage and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data. We may also use web beacons or “pixels,” such as for analytics purposes. We may use these technologies to collect information, such as IP address, screen resolution, browser software, and operating system types, clickstream patterns, dates and times that our site is accessed, and other categories of data. We may also automatically collect certain data about your device, such as information about your web browser, time zone, mobile device ID, model, manufacturer, operating system, version information, carrier-related information, and IDs related to the hardware in your phone as well as the network to which the device is connected, mobile phone number, application-specific and instance-specific identifiers, and location information.
We use “interest-based” ads, also known as “online behavioral advertising.” Interest-based advertising is advertising that is targeted to you based on your web browsing and app usage over time and across websites or apps. You have the option to restrict the use of information for interest-based advertising and to opt-out of receiving interest-based ads. We may partner with ad networks and other advertising providers (“Advertising Providers”) who serve ads on behalf of us and others on non-affiliated sites. Some of these third parties may use cookies and other technologies to collect information about your online activities over time and across third party websites or online services to deliver advertising based on your interests and preferences, as inferred from your browsing history. Some of these ads may be personalized, meaning that they are intended to be relevant to you based on information that we and our Advertising Providers collect about your visits to this site and elsewhere over time, such as your age, gender, approximate geographic location, interests, and ex-patriot status.
To learn more about this type of advertising and how to opt-out of this form of advertising, you may either visit http://www.aboutads.info to opt-out of sites and services participating in the Digital Advertising Alliance (“DAA”) self-regulatory program, or visit http://www.networkadvertising.org/choices/ to opt-out of this form of advertising by members of the Network Advertising Initiative (“NAI”). Note that electing to opt-out will not stop advertising from appearing in your browser or applications, although it may make the ads you see less relevant to your interests. This opt-out works through cookies set on a particular browser, so if you delete cookies from a web browser, or use a different browser, you will need to opt out again. Your choice to opt out on a particular browser or device will apply only to the collection and use of information from that particular browser or device. Opting out on a particular device will not opt you out of information collection on other devices, nor will it limit cross-device sharing on those other devices. If you use different browsers on a device or multiple devices, for each browser and device you wish to opt out, please opt out each device and browser separately.
If you want to block or delete cookies, you should take the necessary steps within your web browser’s settings. Please note that if you choose to delete or block cookies, certain parts of our Site may not function correctly. For information on how to disable cookies, refer to your browser’s settings and instructions.
Our Site currently uses Google Analytics. Please read How Google uses information from sites or apps that use our services for information about how Google Analytics collects and processes data. If you wish to opt out of Google Analytics, please click here.
Social Network Widgets
Our Site may include social network sharing widgets that may provide information to their associated social networks or third parties about your interactions with our web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where widget appears. If you use social network tools or visit social networking sites, we encourage you to read their privacy disclosures to learn what information they collect, use, and share.
Do Not Track
Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an Internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third-parties as defined by the initiative. Please note that the Site does not alter its behavior or use practices when we receive a Do Not Track signal from your browser.
Data Subject Rights Regarding Personal Information
Subject to applicable law, you may have the following rights regarding your personal information, including the right to request confirmation from us as to whether or not we are processing your personal information. Where we are processing your personal information, subject to applicable law, you may also have the right to:
- Request access to, modification of, or correction of your personal information. You may have the right to request access to, modification of, or correction of your personal information. You may also have the right to correct factual errors in your personal information by sending us a request that credibly shows the error.
- Request deletion of your personal information. You may have the right to request that we delete the personal information that we have collected about you.
- Request restriction of processing. You may have the right to request that we restrict processing of your personal information in certain circumstances, such as where you believe that the personal information we hold about you is inaccurate or that our processing is unlawful.
- Object to processing. In certain circumstances, you may have the right to request that we stop processing your personal information, such as a request to stop sending you direct marketing communications. To opt-out of direct marketing communications, please see the instructions in the “Updating Your Communications Preferences and Withdrawing Consent” section of this Privacy Policy.
- Data portability. In certain circumstances, you may have the right to receive the personal information concerning you that you provided to us or to request that we transmit your personal information to another data controller.
- Lodge a Complaint. You may have the right to lodge a complaint with a supervisory authority, should Clinilabs not handle your complaint to your satisfaction. Please contact us first so that we may address your concerns consistent with the standards set forth in this policy. If you are located in the United Kingdom, the supervisory authority may be contacted here; and if you are located in the European Economic Area, you can locate contact information for the relevant supervisory authority here.
To exercise your rights, please contact us at privacy@clinilabs.com. Please note, the above rights may be subject to various exclusions and exceptions under the law, and, under certain circumstances, certain data elements may not be subject to access, modification, portability, restriction, and/or deletion. Furthermore, where permissible, we may charge for this service. We will respond to reasonable requests as soon as practicable and as required by law. Clinilabs reserves the right to decline to handle requests that are frivolous, unreasonable, or made in bad faith. To protect your privacy and security, we will also take steps to verify your identity before responding to your request.
Updating Your Communications Preferences and Withdrawing Consent
Where consent is the basis of processing, you may at any time withdraw the consent you provided for the processing of your personal information for the purposes set forth in this Privacy Policy by contacting us at privacy@clinilabs.com, provided that we are not required by applicable law or professional standards to retain such information.
If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you may do so by following the unsubscribe instructions that appear in these e-mail communications, or you may contact us at privacy@clinilabs.com to opt-out of direct marketing. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices. If you wish to stop receiving SMS/text messages, please send us an email at privacy@clinilabs.com that includes your mobile phone number or reply “STOP” to a SMS/text message. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices.
Please note that if you do not provide consent, if you withdraw your consent or object to processing, or if you choose not to provide certain personal information, we may be unable to provide some or all of our services.
Data Security
Clinilabs is committed to maintaining the confidentiality and privacy of the information you have shared with us. We have put in place reasonable technical, organizational, and physical measures to safeguard and secure the information we collect against accidental or intentional access, disclosure, destruction, loss, or other data incident. Please note, however, we cannot fully eliminate security risks associated with the storage and transmission of personal information.
Children’s Privacy
We do not collect or maintain information from those we actually know are under 18, and no part of our website is intended to be directed at anyone under 18. If you become aware that a minor has provided us with personal information, please contact us at privacy@clinilabs.com. If we become aware that a minor has provided us with personal information without appropriate consent, we will take steps to remove the data as permitted by law.
Transfer of Data
Please note that if you are visiting the Site from outside of the United States, your information may be transferred to, stored, and/or processed in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. If you are located outside of the United States, the transfer of personal information may be necessary to provide you with the requested information and services and/or to perform any requested transaction. By accessing or using any portion of the Site, you acknowledge and consent to the transfer of your information to our facilities in the United States. For individuals located in the EEA or the United Kingdom, we encourage you to familiarize yourself with your rights regarding data transfer under applicable EEA or UK laws and regulations.
Links to Other Sites
Our Site may contain links or otherwise provide access to another website, mobile application, or Internet location (collectively “Third-Party Sites”). Please note that we have no control over and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites. We encourage you to read the privacy policies of any Third-Party Site with which you choose to interact.
Data Retention
We will retain your personal information for as long as is necessary to fulfill the purposes for which we obtained the personal information, including to provide the services, or for such longer period as may be required or permitted by applicable law. We will also retain your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and policies. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the purposes for processing your personal information and associated legal bases; (iii) the existence of a legal obligation as to the retention period; (iv) our contractual obligations; and (v) the advisability of retaining the information in light of our legal position (for example, applicable statutes of limitations, litigation, or regulatory investigations).
Updates to the Privacy Policy
Clinilabs may update this Privacy Policy from time to time to ensure consistency with Clinilabs’ practices, as well as evolving legal and regulatory changes and obligations. The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. Your continued use of our website constitutes your consent to our Privacy Policy, so Clinilabs encourages you to periodically review this Policy to stay informed of how we process your information.
How To Contact Us
Should you have other questions or concerns about this Privacy Policy, please email us at privacy@clinilabs.com or contact us as follows:
Clinilabs Drug Development Corporation
Attn: Privacy Officer
4 Industrial Way West
Eatontown, New Jersey
(646) 215-6400