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Supplemental Privacy Notice for US Residents

Purpose

This US Supplemental Privacy Notice (“Supplemental Notice”) applies only to information collected about consumers in certain states, including California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia. 
Some portions of this Supplemental Notice apply only to consumers of particular states. This Supplemental Notice forms part of and supplements and amends, as applicable, our Privacy Policy. 

Personal Information We Collect

Depending on your interaction with us, we may collect the following categories of personal information about you:

  • Identifiers, such as name, initials, patient ID, phone number, mailing address, email address, online identifiers, date of birth, IP address, device ID, or similar identifiers;
  • Characteristics of protected classifications under applicable state or federal law, such as age, gender, race, physical or mental health conditions, disability, sex and marital status;
  • Internet or other electronic network activity information, such as interactions with our websites, emails, or advertisements; IP address, browser type, device type and operating system, browsing and search history, clickstream data, the language and date of your visit, the length of time you visit our website, and the referring URL, webpage, or application that led you to our website; and access logs and other activity information related to your use of our website;
  • Geolocation data, such as the approximate or precise physical location of your device or internet connection (only for our TrialMax service if there is a connected study device which requires Bluetooth connection);
  • Commercial information, such as your username and password, transaction history, products or services obtained or considered, preferences, content viewed, and the contents of your communications with us;
  • Audio, visual and similar information, such as call and video recordings;
  • Professional or employment-related information, such as specialty, education history, professional qualifications, work history and prior employers;
  • Inferences, such as those drawn from the information above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, aptitudes or abilities.
  • Sensitive personal information, as defined under applicable law, such as your precise geolocation; racial or ethnic origin; health information; sex life or sexual orientation; and login credentials and passwords.
Retention of Personal Information. We retain your Personal Information for the period necessary to provide our services to you and for the period necessary to support our business operational purposes, unless a longer retention period is required or permitted by applicable law.  We retain information in accordance with applicable law, including for the purpose of satisfying any legal, regulatory, accounting, or other reporting requirements and as otherwise necessary to fulfill the purposes outlined in this Supplemental Notice and our Privacy Policy.  When assessing retention periods, we first examine whether it is necessary to retain information and, if retention is required, work to retain the information for permissible periods under applicable law.  

Sources of Personal Information

We collect the categories of Personal Information listed above from the following categories of sources:

  • Directly from you, including when you provide information to us;
  • Indirectly from you, such as when we automatically collect technical and usage information (e.g. via cookies and similar technologies) or when your caregiver, health care professional or our client provides us information about you;
  • Public sources, such as LinkedIn and other professional websites;

Purposes for which We Collect and Use Personal Information

We may use the Personal Information listed above for the following business and commercial purposes:

  • To provide our clinical trial services to our clients, including maintaining and updating information as-needed to ensure accuracy;
  • To respond to your inquiries;
  • To provide, support, personalize, and develop our website, applications, and product or service offerings;
  • To prevent malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity;
  • To debug, identify, or repair errors or effectuate similar functional enhancements in connection with our website or services;
  • For internal operational uses such as research, analytics, development, audits, and security;
  • For legal and operational compliance purposes, such as monitoring whether our operations are effectively implementing this policy;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding
  • To engage in or enable internal uses consistent with our relationship with you, or compatible with the context in which you provided the information, such as internal research and development; and
  • For any other purpose described to you when collecting your Personal Information before or at the time of collection.
  • We do not use or disclose sensitive personal information for purposes other than permitted under applicable law.
  • To deidentify or anonymize your data in such a way that you may not reasonably be reidentified by us or another party, and we may use such deidentified data for any purposes permitted under applicable law.  To the extent we deidentify data originally based on personal information, we will maintain and use such data in deidentified form and will not attempt to reidentify that data, except as permitted under applicable law. 

Disclosures of Personal Information

The table below describes the categories of third parties to whom we may disclose the categories of information we collect about you for our business and commercial purposes as a business.

We do not “sell” or “share” (as those terms are defined under applicable law) personal information with third parties.    

Category of Information We Collect Categories of Third Parties to Whom We Disclose
Identifiers
  • Our affiliated companies,
  • Our service providers, such as hosting services, mailing, email/SMS messaging, helpdesk, only to the extent needed for them to provide the service
  • Professional advisors and service providers, such as auditors, accountants, attorneys, only to the extent needed for them to provide the service
  • Government entities and legal authorities, such as law enforcement, regulatory agencies, courts, and other governmental authorities when required by law or to protect our legal rights.
  • Other third parties involved in a merger, acquisition, sale, joint venture or other transaction involving a transfer of our business or assets.
  • Clinical trial sites and sponsors, if you are a patient in a clinical trial
  • Sponsors and CROs, if you are a health care provider who supports clinical trials
Characteristics of protected classifications under applicable law
  • Our affiliated companies,
  • Our service providers, such as hosting services, only to the extent needed for them to provide the service
  • Professional advisors and service providers, such as auditors, accountants, attorneys, only to the extent needed for them to provide the service
  • Government entities and legal authorities, such as law enforcement, regulatory agencies, courts, and other governmental authorities when required by law or to protect our legal rights.
  • Other third parties involved in a merger, acquisition, sale, joint venture or other transaction involving a transfer of our business or assets.
  • Clinical trial sites and sponsors, if you are a patient in a clinical trial
Internet or other electronic network activity 
  • Our affiliated companies,
  • Our service providers, such as hosting services, cookie management service providers, only to the extent needed for them to provide the service
  • Professional advisors and service providers, such as auditors, accountants, attorneys, only to the extent needed for them to provide the service
  • Government entities and legal authorities, such as law enforcement, regulatory agencies, courts, and other governmental authorities when required by law or to protect our legal rights.
  • Other third parties involved in a merger, acquisition, sale, joint venture or other transaction involving a transfer of our business or assets.
  • Marketing and analytics partners, companies that help us analyze website usage and trends and advertise.
Geolocation data
  • Our affiliated companies,
  • Our service providers, such as hosting services, only to the extent needed for them to provide the service
  • Professional advisors and service providers, such as auditors, accountants, attorneys, only to the extent needed for them to provide the service
  • Government entities and legal authorities, such as law enforcement, regulatory agencies, courts, and other governmental authorities when required by law or to protect our legal rights.
  • Other third parties involved in a merger, acquisition, sale, joint venture or other transaction involving a transfer of our business or assets.
Commercial information
  • Our affiliated companies,
  • Our service providers, such as hosting services, only to the extent needed for them to provide the service
  • Professional advisors and service providers, such as auditors, accountants, attorneys, only to the extent needed for them to provide the service
  • Government entities and legal authorities, such as law enforcement, regulatory agencies, courts, and other governmental authorities when required by law or to protect our legal rights.
  • Other third parties involved in a merger, acquisition, sale, joint venture or other transaction involving a transfer of our business or assets.
Audio, visual, and similar information
  • Our affiliated companies,
  • Our service providers, such as hosting services, professionals who perform quality reviews, only to the extent needed for them to provide the service
  • Professional advisors and service providers, such as auditors, accountants, attorneys, only to the extent needed for them to provide the service
  • Government entities and legal authorities, such as law enforcement, regulatory agencies, courts, and other governmental authorities when required by law or to protect our legal rights.
  • Other third parties involved in a merger, acquisition, sale, joint venture or other transaction involving a transfer of our business or assets.
  • Clinical trial sites and sponsors, if you are a patient in a clinical trial
  • Sponsors and CROs, if you are a health care provider who supports clinical trials
Professional or employment related information
  • Our affiliated companies,
  • Our service providers, such as hosting services, mailing, email/SMS messaging, benefit providers, only to the extent needed for them to provide the service
  • Professional advisors and service providers, such as auditors, accountants, attorneys, only to the extent needed for them to provide the service
  • Government entities and legal authorities, such as law enforcement, regulatory agencies, courts, and other governmental authorities when required by law or to protect our legal rights.
  • Other third parties involved in a merger, acquisition, sale, joint venture or other transaction involving a transfer of our business or assets.
  • For employees: as described in the Employee Privacy Notice
Inferences
  • Our affiliated companies,
  • Our service providers, such as hosting services, only to the extent needed for them to provide the service
  • Professional advisors and service providers, such as auditors, accountants, attorneys, only to the extent needed for them to provide the service
  • Government entities and legal authorities, such as law enforcement, regulatory agencies, courts, and other governmental authorities when required by law or to protect our legal rights.
  • Other third parties involved in a merger, acquisition, sale, joint venture or other transaction involving a transfer of our business or assets.
Sensitive personal information 
  • Our affiliated companies,
  • Our service providers, such as hosting services, only to the extent needed for them to provide the service
  • Professional advisors and service providers, such as auditors, accountants, attorneys, only to the extent needed for them to provide the service
  • Government entities and legal authorities, such as law enforcement, regulatory agencies, courts, and other governmental authorities when required by law or to protect our legal rights.
  • Other third parties involved in a merger, acquisition, sale, joint venture or other transaction involving a transfer of our business or assets.
  • Clinical trial sites and sponsors, if you are a patient in a clinical trial

 

Your Rights and Choices with Respect to Personal Information

Subject to applicable exceptions, and except as otherwise noted, you have the following rights under applicable U.S. state privacy laws: 

  • Access and Data Portability Rights: You may request, up to twice every 12 months, a copy of the specific pieces of personal data that we have collected, used or disclosed about you in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows you to transmit this information to another entity without hindrance. You have the right to request that we disclose to you the following information in respect of our collection and use of your Personal Information over the past 12 months:
    • The categories of Personal Information we collected about you.
    • The categories of sources for the Personal Information we collected about you;
    • Our business or commercial purpose for collecting or selling your Personal Information;
    • The categories of third parties with whom we share your Personal Information;
    • The specific pieces of Personal Information we collected about you;
    • If we sold or shared your Personal Information for a business purpose, including separate lists for disclosures for a business purpose, identifying the Personal Information categories disclosed; and sales, identifying the Personal Information categories sold and that each category of recipient purchased.
  • Obtain a List of Specific Third Parties:  If you are a resident of certain states, including Delaware, Oregon, and Minnesota, you have a right to request a list of the specific third parties to whom we have disclosed your personal information.
  • Correction: You may request correction of your Personal Information that we have collected about you if it is inaccurate or incomplete.
  • Deletion: You may request deletion of your Personal Information that we have collected about you, subject to certain exceptions.
  • Right to Opt Out of “Sharing,”  “Sale,” and Targeted Advertising: We do not “sell” or “share” (as those terms are defined under applicable law) your personal information with third parties.  If you have enabled a legally recognized browser-based opt out preference signal (such as Global Privacy Control) on your browser, we recognize such preference in accordance and to the extent required by applicable law. Please note that this signal will be linked only to your browser or device.  You can learn more about how to use the Global Privacy Control.   
  • Right to Non-Discrimination: You have the right not to be discriminated against for exercising your rights under applicable law. We will not discriminate against you for exercising your rights.

Exercising Your Rights

To exercise your rights described above, or if you are an authorized agent submitting a request on behalf of a consumer under applicable law, please submit your request to us by:

You or your authorized agent may be asked to provide information such as your name or your email address to verify your identity.  Authorized agents may also be required to provide a copy of your signed permission authorizing the agent to submit a request on your behalf.  

You may have a right to appeal a decision we make relating to requests to exercise your rights under applicable local law. If your request is denied or if we do not take action on your request, we will inform you in writing of the reasons for not taking action, as well as provide an explanation of any rights you have to appeal the decision.  To appeal a decision we have made relating to your privacy rights request under applicable law, please contact us by sending an email to dpo@signanthealth.com or contact us via our website, at https://signanthealth.com/company/contact-us .  

Changes to this Supplemental Notice

We reserve the right to amend this Supplemental Notice at our discretion at any time. When we make changes to this Supplemental Notice, we will post the updated Notice on our website.